ii. Where the allegations made in the FIR and the evidence collected by the police in support of the allegations do not point towards the guilt of the accused. iii. Where investigation has been carried out by the police in a noncognizable offence without the order of a magistrate. iv. Where the Cr PC or any other law expressly prohibits carrying out criminal proceedings against the accused. v. Where criminal proceedings have been started with dishonest intent to take revenge from the accused. Non-registration of First Information Reports [FIR] is one of the most serious, frequent and common grievances against the police. This problem is compounded when the person against whom a complaint is made is rich and powerful. Article 14 of the Constitution guarantees to all persons’ equality before the law and equal protection of the laws within the territory of India. Police officers must register an FIR immediately on receiving information about a cognizable offence. Persons aggrieved by nonregistration of FIR can approach the District Superintendent of Police or the concerned Magistrate to get their complaints registered. Alternatively complaints in this regard can also be filed before the National or concerned State Human Rights Commission. II. Basis of Investigation State of West Bengal v Swapan Kumar Guha & others 1982 SCC 561 A. Background Sanchaita Investments of Calcutta was offering extraordinarily high rates of interest to attract cash deposits from the public. The Commercial Tax Officer, Bureau of Investigation suspected some fraud was being committed. He asked the police to register a First Information Report [FIR] on the grounds that such high rates of interest could not be sustained, therefore the deposit scheme was being promoted with the intention of making quick or easy money, in violation of the Prize Chits and Money Circulations Schemes [Banning] Act, 1978. The police registered an FIR and started an investigation on the basis of the Commercial Tax Officer’s suspicions. However, the High Court cancelled the FIR and subsequent police proceedings, saying that they were Manual on Human Rights for Police Officers 65