01/08/2026
Types of Police Reports (Challans) under Section 173 of the Code of Criminal Procedure, 1898: Judicial Commentary
Prefatory Note
Although the nomenclature and classification of police reports (commonly referred to as challans) may vary under the Police Rules and administrative practices of different Provinces, the governing legal principles emanate from Section 173 of the Code of Criminal Procedure, 1898 ("CrPC"), and the judicial pronouncements interpreting the same. The following is a concise exposition of the principal categories of police reports recognized in criminal practice.
1. Complete Challan (Complete Police Report)
Definition
A Complete Challan is the Police Report submitted upon conclusion of the investigation, after the investigating agency has collected all available evidence, recorded the statements of witnesses, secured the necessary medico-legal and forensic reports, identified the accused, and compiled all material documents required for prosecution.
Judicial Commentary
A Complete Challan constitutes the principal Police Report contemplated by Section 173 CrPC. Upon its submission, the Court is required to examine whether sufficient grounds exist for proceeding against the accused in accordance with law. Where the material placed before the Court discloses a prima facie case, the matter proceeds to trial. Such report ordinarily comprises the statements of witnesses, documentary evidence, recovery memos, medical and forensic reports, and every other document relied upon by the prosecution.
2. Incomplete Challan (Interim Police Report)
Definition
Where the investigation remains incomplete but the statutory period prescribed for submission of the Police Report is about to expire, or circumstances otherwise necessitate an immediate report to the Court, the investigating agency may submit an Interim or Incomplete Challan.
Judicial Commentary
The object of an Interim Challan is not to conclude the investigation but to prevent undue delay in criminal proceedings. The remaining investigation is thereafter completed, and any additional material is placed before the Court by means of a Supplementary Challan under Section 173(8) CrPC.
3. Supplementary Challan (Section 173(8) CrPC)
Definition
Where, after submission of the original Police Report, fresh evidence, additional witnesses, newly discovered accused persons, or other material facts emerge, the investigating agency may conduct further investigation and submit a Supplementary Challan.
Judicial Commentary
Section 173(8) CrPC expressly preserves the authority of the investigating agency to undertake further investigation even after submission of the original Police Report. A Supplementary Challan neither supersedes nor invalidates the original report; rather, both reports constitute a composite record and must be read harmoniously. Supplementary reports commonly arise upon receipt of forensic analyses, DNA reports, expert opinions, or discovery of additional incriminating evidence.
4. Cancellation Report
Definition
Where the investigation reveals that no offence is made out or that continuation of the criminal proceedings lacks legal justification, the investigating agency may recommend cancellation of the First Information Report by submitting a Cancellation Report before the competent Court.
Judicial Commentary
The opinion of the investigating agency is merely recommendatory and is not binding upon the Court. The Court may accept the recommendation, reject it, direct further investigation, or take cognizance of the offence independently if the material available justifies such course. The ultimate determination rests exclusively within the judicial domain.
5. Untraced Report (A-Class)
Definition
An Untraced Report is submitted where the commission of the offence is established but the offender cannot be identified or apprehended despite diligent investigation.
Judicial Commentary
Such a report does not dispute the occurrence of the offence. It merely records the inability of the investigating agency to trace or identify the perpetrator. Should the offender subsequently be identified or arrested, the investigation and prosecution may lawfully be revived.
6. False Case Report (B-Class)
Definition
Where the investigation affirmatively establishes that the complaint was false, malicious, or instituted with ulterior motives, the investigating agency may submit a B-Class Report.
Judicial Commentary
A B-Class Report signifies more than a mere deficiency of evidence; it embodies the investigating agency's conclusion that the complaint itself was knowingly false or actuated by mala fides. Upon acceptance of such report, the Court may, where circumstances so warrant, initiate proceedings against the complainant in accordance with law. Nevertheless, the Court is not bound by the investigative opinion and may independently evaluate the material before it.
7. Further Investigation Report (Section 173(8) CrPC)
Definition
A Further Investigation Report is the report submitted upon completion of additional investigation undertaken under Section 173(8) CrPC, whether on the initiative of the investigating agency or pursuant to judicial directions.
Judicial Commentary
In practice, the expressions "Further Investigation Report" and "Supplementary Challan" are frequently employed interchangeably. Such report merely supplements the original Police Report and does not extinguish or replace it. Both reports collectively constitute the prosecution record for purposes of judicial consideration.
8. Absconder Challan
Definition
Where an accused absconds and is declared a Proclaimed Offender by the competent Court, the investigating agency may submit an Absconder Challan in respect of such accused.
Judicial Commentary
The pendency of proceedings against an absconding accused does not impede the prosecution of co-accused who are available before the Court. Upon subsequent arrest or surrender, the proclaimed offender may be tried separately in accordance with law.
9. Split Challan
Definition
A Split Challan is submitted where, in the same criminal case, some accused have been apprehended while others continue to abscond.
Judicial Commentary
This procedure enables the Court to proceed against the accused who are before it without awaiting the apprehension of absconding co-accused, thereby preventing avoidable delay in the administration of criminal justice.
10. Challan in Respect of an Accused in Custody
Definition
This is a Police Report submitted where the accused remains in judicial or police custody at the time of filing of the Challan.
Judicial Commentary
Upon submission of such report, the Court considers matters relating to remand, judicial custody, framing of charge, and commencement of trial. The investigating agency is under a statutory obligation to submit the report within the prescribed period, failing which the rights of the accused under the law may be affected.
11. Challan in Respect of an Accused on Bail
Definition
Where the accused has been admitted to pre-arrest or post-arrest bail, the Police Report is submitted while the accused continues to enjoy the concession of bail.
Judicial Commentary
Submission of the Challan does not, by itself, operate to cancel the bail. The Court retains jurisdiction to maintain, modify, or revoke the order of bail upon consideration of the material placed before it. The accused remains under a continuing obligation to appear before the Court whenever required.
12. Electronic or Digital Challan
Definition
An Electronic or Digital Challan is a Police Report prepared, maintained, and submitted through an electronic or computerized case management system.
Judicial Commentary
The adoption of electronic case management promotes transparency, efficiency, accountability, and preservation of official records. With the gradual implementation of e-governance and digital judicial systems, electronic submission of Police Reports has assumed increasing significance in the administration of criminal justice.
Concluding Principle
The fundamental object of Section 173 CrPC is to ensure that, upon completion of the investigation, the investigating agency places before the competent Court a fair, complete, and comprehensive Police Report, thereby enabling the Court to determine whether sufficient legal grounds exist to proceed with the prosecution. The submission of the Police Report marks the culmination of the investigative process; however, it does not preclude further investigation. Where subsequent facts or evidence come to light, Section 173(8) CrPC expressly authorizes the investigating agency to conduct further investigation and to submit a Supplementary Police Report, which forms part of the original record and must be considered together therewith.
Clarificatory Note
As a matter of established criminal practice, the expressions "Supplementary Challan" and "Further Investigation Report" generally denote the same legal concept founded upon Section 173(8) CrPC.
