Police Cannot Register FIR And Conduct Investigation For PC-PNDT Act Offences

Supreme Court Landmark Judgment: The State of Uttar Pradesh v. Brij Pal Singh (2026)

Supreme Court of India August 20, 2026 Criminal Law / Medical Law 15 min read

1. Introduction: Why This Judgment Matters
2. Case Background & Factual Matrix
3. The PC-PNDT Act: Legal Framework
4. The Three Questions Before the Supreme Court
5. Interplay Between Section 27 & Section 28
6. Supreme Court's Detailed Reasoning
7. Question (A): Permissibility of FIR Registration
8. Question (B): Permissibility of Police Investigation
9. Question (C): Cognizance on Police Chargesheet
10. Justice Kotiswar Singh's Supplementary Opinion
11. Practical Implications & Future Impact
12. Comparative Analysis: Special vs. General Law
13. Conclusion & Key Takeaways

1Introduction: Why This Judgment Matters

In a landmark ruling that reshapes the enforcement landscape of India's fight against female foeticide, the Supreme Court of India delivered a path-breaking judgment on August 20, 2026, holding that police cannot register an FIR or conduct investigations for offences under the Pre-Conception and Pre-Natal Diagnostic Techniques (Prohibition of Sex Selection) Act, 1994 (commonly known as the PC-PNDT Act). The case, The State of Uttar Pradesh v. Brij Pal Singh, arose from a reference made by the Allahabad High Court and has settled one of the most contentious procedural questions surrounding this socially beneficial legislation.

The PC-PNDT Act was enacted with the solemn objective of prohibiting the misuse of prenatal diagnostic techniques for sex determination, thereby preventing the alarming practice of female foeticide that has plagued Indian society for decades. Despite being declared cognizable, non-bailable, and non-compoundable under Section 27 of the Act, the Supreme Court has now clarified that these classifications do not automatically empower the police to assume the role of primary investigators. Instead, the Court reinforced the statutory scheme that designates the Appropriate Authority as the sole entity responsible for investigating complaints and initiating prosecutions under this specialised legislation.

This judgment is not merely a technical interpretation of statutory provisions. It represents a profound understanding that certain offences require domain-specific expertise, medical knowledge, and institutional sensitivity that general police forces may lack. For legal practitioners, medical professionals, law enforcement agencies, and civil society organisations working toward gender justice, this ruling provides much-needed clarity on the procedural architecture of one of India's most important social welfare legislations. To understand the broader framework of how FIRs work in India, you may refer to our comprehensive guide on What Happens After an FIR Is Filed.

2Case Background & Factual Matrix

The origins of this case trace back to a secret information received by authorities regarding sex determination activities being carried out at Soba Ram Hospital. The information suggested that the sex identification of foetuses of pregnant women was being conducted with the explicit objective of avoiding the birth of girl children — a practice that strikes at the very heart of the PC-PNDT Act's prohibition. Acting on this intelligence, the District Appropriate Authority meticulously planned a decoy operation designed to catch the perpetrators red-handed.

The operation was executed with precision. A decoy pregnant woman was sent to the hospital, and the team successfully reached the actual doctor involved in these illegal activities — the petitioner, Dr. Brij Pal Singh. Following the successful sting operation, an FIR was registered by Sub-Inspector Subhash Singh on the dictation of the Tehsildar, with all members of the police team signing as witnesses. A chargesheet was subsequently filed before the Chief Judicial Magistrate, and the criminal case was registered.

Dr. Brij Pal Singh, however, challenged the entire proceedings before the Allahabad High Court, contending that under Section 28 of the PC-PNDT Act, a case could only be initiated by the Appropriate Authority through a formal complaint, and not through the registration of an FIR by the police. The High Court, by its judgment dated September 30, 2024, referred three specific questions of law to the Supreme Court for authoritative determination, recognising the profound implications this issue held for the enforcement of the Act across India.

Case Details at a Glance

Case Title: The State of Uttar Pradesh and Anr. v. Brij Pal Singh and Anr.
Court: Supreme Court of India
Bench: Justice Sanjay Karol & Justice N. Kotiswar Singh
Date of Judgment: August 20, 2026
Citation: 2026 LiveLaw (SC) 842
Case Number: Crl.A. No. 2938/2025 (Diary No. 22340/2025)
Impugned Order: Allahabad High Court judgment dated September 30, 2024

3The PC-PNDT Act: Legal Framework

The Pre-Conception and Pre-Natal Diagnostic Techniques (Prohibition of Sex Selection) Act, 1994 represents one of Parliament's most significant interventions to address the declining child sex ratio in India. The Act was enacted to ban the use of sex selection techniques before or after conception and to prevent the misuse of prenatal diagnostic techniques for sex-selective abortion. It is a socially beneficial legislation that falls within the constitutional sweep of Article 15(3) and Article 39 of the Constitution of India, designed to protect the dignity and right to life of the unborn female child.

The Act creates a comprehensive regulatory framework that includes:

Provision	Subject Matter	Key Content
Section 2(bc)	Definition of "Foetus"	Human organism from the 57th day following fertilization until birth
Section 2(i)	Pre-natal Diagnostic Procedures	Includes ultrasonography, foetoscopy, amniocentesis, chorionic villi sampling, and other techniques
Section 4	Prohibition of Sex Selection	No person shall use or cause to be used any pre-natal diagnostic technique for the purpose of determining the sex of a foetus
Section 5	Prohibition of Communication of Sex	No person shall communicate the sex of the foetus to the pregnant woman or her relatives
Section 6	Prohibition of Sex-Selective Abortion	No person shall conduct or cause to be conducted any pre-natal diagnostic techniques including ultrasonography for the purpose of sex determination
Section 17	Appropriate Authority	Constitution, powers, and functions of the Appropriate Authority at Central and State levels
Section 17(4)	Investigation of Complaints	Appropriate Authority responsible for investigating complaints, taking immediate action, and initiating independent investigations
Section 17A	Power to Summon	Authority empowered to summon persons, require documents, and issue search warrants
Section 27	Nature of Offences	All offences under the Act declared cognizable, non-bailable, and non-compoundable
Section 28	Cognizance of Offences	No court shall take cognizance except on complaint by Appropriate Authority or authorised officer, or by a person who has given 15 days' notice
Section 30	Search and Seizure	Appropriate Authority may conduct searches and seizures with necessary assistance; applies CrPC provisions relating to searches and seizures

The Appropriate Authority is the linchpin of this statutory framework. Constituted under Section 17, this body comprises medical experts, government officers, and other stakeholders who possess the technical knowledge necessary to evaluate complex medical evidence. The Authority is vested with powers to investigate complaints, conduct searches, seize equipment, summon witnesses, and file complaints before the Magistrate — functions that require specialised expertise far beyond the training of ordinary police personnel. For a deeper understanding of how specialised authorities function within India's legal framework, explore our analysis of Section 9 of BNSS — Courts of Judicial Magistrates.

4The Three Questions Before the Supreme Court

The Allahabad High Court, in its wisdom, recognised that the case raised fundamental questions about the interplay between the general criminal procedure (governing FIR registration and police investigation) and the special procedure established under the PC-PNDT Act. It therefore referred the following three questions to the Supreme Court for authoritative determination:

Q.No.	Question Referred	Core Legal Issue
(A)	Whether, for the offences under the PC & PNDT Act, the registration of FIR at the Police Station is permissible, merely because the offences under the PC & PNDT Act have been made cognizable and non-bailable?	Scope of police power to register FIR under special legislation
(B)	Whether the Police investigation is permissible for the offences under the PC & PNDT Act? AND Who can investigate the complaints received for violation of the provisions of the PC & PNDT Act?	Locus standi of police vs. Appropriate Authority in investigation
(C)	Whether on the charge sheet submitted after the investigation by the Police, the competent magistrate can take cognizance of the offence under the PC & PNDT Act?	Validity of cognizance on police chargesheet under Section 28

The Supreme Court, exercising its jurisdiction under Article 134A read with Article 136 of the Constitution, accepted the reference and proceeded to examine these questions with the assistance of Senior Advocate Mukta Gupta and Advocate-on-Record Nitin Saluja, who assisted the Court as Amicus Curiae. The Union of India was represented by Additional Solicitor General Vikramjit Banerjee, while AOR Vishwa Pal Singh appeared for the State of Uttar Pradesh.

5Interplay Between Section 27 & Section 28: The Heart of the Conflict

The central tension in this case arose from the apparent conflict between Section 27 and Section 28 of the PC-PNDT Act. Section 27 declares every offence under the Act to be cognizable, non-bailable, and non-compoundable. Under general criminal law, as codified in the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 (formerly Section 154 of the CrPC), the classification of an offence as "cognizable" empowers the police to register an FIR without prior judicial authorisation and to commence investigation immediately, including the power to arrest without warrant.

However, Section 28 creates a special procedural framework for taking cognizance of offences. It states that no court shall take cognizance of an offence under the Act except on a complaint made by:

(a) The Appropriate Authority concerned, or any officer authorised in this behalf by the Central Government, State Government, or the Appropriate Authority; or
(b) A person who has given notice of not less than fifteen days in the prescribed manner to the Appropriate Authority, of the alleged offence and of his intention to make a complaint to the court.

The prosecution argued that since Section 27 makes offences cognizable, the general police powers under the BNSS must apply, and the police can therefore register FIRs and investigate these offences like any other cognizable crime. The defence, conversely, contended that Section 28 creates a complete statutory mechanism that ousts the general procedure, and that the special nature of the Act demands specialised investigation by the Appropriate Authority alone.

The Supreme Court was called upon to resolve this interpretative conflict, keeping in mind the socially beneficial nature of the Act, the technical and medical expertise required for investigating such offences, and the legislative intent behind creating a dedicated Appropriate Authority. Understanding the distinction between cognizable and non-cognizable offences is crucial here — read our detailed guide on What Happens After an FIR Is Filed for more context.

6Supreme Court's Detailed Reasoning

The Supreme Court, speaking through Justice Sanjay Karol, delivered a comprehensive judgment that examined the scheme of the Act, the legislative intent, the interplay between special and general law, and the practical consequences of each possible interpretation. The Court's reasoning can be distilled into several key pillars:

6.1 Special Law Prevails Over General Law

The Court reaffirmed the well-settled principle of statutory interpretation that when a special statute creates a complete code for dealing with specific subject matter, the general law must yield to the special law. The PC-PNDT Act is not a general criminal statute; it is a specialised legislation dealing with highly technical medical procedures, diagnostic equipment, and ethical standards in medical practice. Parliament deliberately created the Appropriate Authority as a body with medical and technical expertise precisely because ordinary police officers lack the training to evaluate whether a particular ultrasound was conducted for legitimate medical purposes or for illegal sex determination.

6.2 The Statutory Scheme Indicates Legislative Intent

The Court meticulously examined the provisions of the Act to discern legislative intent. It noted that Section 17(4) expressly assigns the Appropriate Authority the function of investigating complaints, taking immediate action, and initiating independent investigations. Section 17A gives the Authority powers to summon persons, require documents, and issue search warrants. Section 30 empowers the Authority to conduct searches and seizures with such assistance as it considers necessary. Crucially, the Court observed that Section 30 specifically applies the CrPC provisions relating to searches and seizures, indicating that Parliament expressly incorporated general criminal procedure only where it intended to do so. The absence of any similar incorporation of police investigation powers under Chapter XIII of the BNSS was significant.

6.3 The "Logical Conclusion" Test

One of the Court's most powerful arguments was the "logical conclusion" test. The Court reasoned that if the police were permitted to register an FIR and investigate offences under the Act, they would eventually file a chargesheet before the Magistrate. However, Section 28 bars the Magistrate from taking cognizance on a police chargesheet — cognizance is permitted only on a complaint by the Appropriate Authority or a person who has given 15 days' notice. Therefore, a police investigation would be a procedural dead-end: the police could investigate, but the fruits of that investigation could never lead to valid cognizance and trial. The Court held that Parliament could not have intended such a futile exercise, and therefore the power to investigate must rest exclusively with the Appropriate Authority.

6.4 Sensitivity and Medical Expertise

The Court emphasised that the PC-PNDT Act deals with matters requiring medical knowledge, technical assessment of diagnostic equipment, and sensitivity toward pregnant women. Police officers, however well-intentioned, are not trained to distinguish between a legitimate medical ultrasound and an illegal sex determination procedure. They are not equipped to evaluate whether a genetic clinic maintains proper records, whether a radiologist is qualified, or whether an ultrasound machine has been illegally modified. The Appropriate Authority, by contrast, comprises experts who can make these determinations accurately and fairly.

"The language of the statute, more particularly Sections 27 and 28 of the Act when read together, in light of the other provisions and the socially beneficial nature of the Act as also the requirement of sensitivity along with medical and technical know-how, indicates that the police are not meant to be the investigators for the purpose of this Act." — Supreme Court of India, The State of Uttar Pradesh v. Brij Pal Singh (2026)

7Question (A): Permissibility of FIR Registration by Police

The first question before the Court was whether the mere fact that offences under the PC-PNDT Act are declared cognizable and non-bailable under Section 27 independently permits the registration of FIRs by the police. The Supreme Court answered this question in the negative.

The Court held that Section 27 cannot be read in isolation from Section 28 and the other provisions of the Act. While Section 27 classifies the nature of offences, it does not create a standalone power in the police to register FIRs. The classification as "cognizable" serves other purposes — it determines the bail jurisdiction, the compounding status, and the seriousness of the offence — but it does not override the special complaint mechanism established under Section 28. The Court noted that if Parliament had intended the police to register FIRs, it would have expressly said so, as it did in Section 30 by expressly applying CrPC provisions to searches and seizures conducted by the Appropriate Authority.

The Court further observed that the Rule 18A(3)(iv) of the PC-PNDT Rules, which has statutory force, requires that "further recourse to the police be avoided as far as possible." This subordinate legislation, made under the Act, reinforces the legislative intent that police involvement should be minimised and that the Appropriate Authority must remain the primary enforcement agency.

Holding on Question (A)

The registration of FIR at the police station is NOT permissible merely because the offences under the PC-PNDT Act have been made cognizable and non-bailable. The police are not meant to be the investigators for the purpose of this Act. The restriction applies only to offences under this Act and does not restrict the police's power to investigate or prosecute independent offences disclosed under substantive criminal law (IPC/BNS).

For readers interested in understanding when police can legitimately register FIRs and the boundaries of their powers, our article on Can Police Arrest You Without a Warrant? provides essential guidance on police powers and citizen rights.

8Question (B): Permissibility of Police Investigation & Locus of Investigation

The second question was twofold: whether police investigation is permissible for PC-PNDT offences, and who is authorised to investigate complaints received for violation of the Act. The Supreme Court answered both parts comprehensively.

The Court held that police cannot be the main investigative authority under the PC-PNDT Act. At most, the police may play a supplemental role when required by the Appropriate Authority in accordance with the provisions of the Act. This supplemental role is limited to providing assistance such as protection, tracing accused persons, digital or forensic assistance, and preservation of crime scenes — but never to displace the Appropriate Authority's primary responsibility for investigating the PC-PNDT offence itself.

The Court grounded this holding in Section 17(4), which makes investigation of complaints a statutory responsibility of the Appropriate Authority. The Court reasoned that if the police were permitted to investigate and file a chargesheet, the Magistrate would be powerless to take cognizance because of the bar under Section 28. An interpretation permitting police investigation would therefore render such investigation incapable of being taken to its logical conclusion under the statutory scheme. The Court applied the principle that statutes must be interpreted to avoid absurdity, and an interpretation that creates a procedural impasse must be rejected.

Holding on Question (B)

Police investigation is NOT permissible as the main investigative authority for offences under the PC-PNDT Act. The Appropriate Authority is the sole entity responsible for investigating complaints, taking immediate action, and initiating independent investigations. The police can play only a supplemental role when specifically required by the Appropriate Authority.

This principle of limited police role in specialised investigations aligns with broader trends in Indian criminal procedure. For instance, in economic offences and cybercrimes, specialised agencies often take the lead. You can read more about how investigations are structured under the new BNSS in our guide on What Happens After an FIR Is Filed.

9Question (C): Cognizance on Police Chargesheet

The third question addressed the critical issue of whether a competent Magistrate could take cognizance of a PC-PNDT offence based on a chargesheet filed after police investigation. The Supreme Court answered this question with an unequivocal NO.

The Court held that Section 28 creates a complete statutory mechanism for taking cognizance, subject only to the specific situations provided under the provision. The Magistrate's power to take cognizance is strictly limited to complaints filed by:

The Appropriate Authority or its authorised officer; or
A private complainant who has complied with the 15-day notice requirement.

A chargesheet filed by the police pursuant to an FIR and investigation is not one of the recognised modes of initiating proceedings under the Act. The Court emphasised that this is not a mere technicality but a substantive statutory bar designed to ensure that prosecutions are initiated only by entities with the requisite expertise and after proper evaluation of the technical evidence. The Court consequently held that a competent Magistrate cannot take cognizance of an offence under the PC-PNDT Act on the basis of a chargesheet filed pursuant to a police investigation.

Mode of Initiation	Validity Under Section 28	Remarks
Police FIR + Investigation + Chargesheet	INVALID	Magistrate cannot take cognizance; entire proceedings void ab initio
Complaint by Appropriate Authority	VALID	Primary and preferred mode of initiation
Complaint by Authorised Officer (Central/State Govt.)	VALID	Must be authorised in writing by the Appropriate Authority or Government
Private Complaint after 15-Day Notice	VALID	Notice must be given in prescribed manner to the Appropriate Authority

Holding on Question (C)

A competent Magistrate CANNOT take cognizance of an offence under the PC-PNDT Act on the basis of a chargesheet filed after investigation by the police. Cognizance is permissible only on a complaint as defined in Section 28 of the Act.

10Justice N. Kotiswar Singh's Supplementary Opinion

Justice N. Kotiswar Singh delivered a supplementary opinion that added valuable clarity to the scope and limits of the judgment. His Lordship emphasised that while the police cannot be the primary investigators for PC-PNDT offences, this does not render them entirely irrelevant to the enforcement of the Act. The supplementary opinion clarified several important aspects:

10.1 Permissible Police Assistance

Justice Kotiswar Singh clarified that police assistance may still be sought by the Appropriate Authority for specific purposes such as:

Providing protection to enforcement teams during raids and decoy operations;
Tracing accused persons who have absconded;
Providing digital or forensic assistance beyond the Authority's technical capacity;
Preservation of crime scenes and maintenance of law and order during enforcement actions.

10.2 The "Two-Track" Procedural Framework

His Lordship introduced the concept of a "two-track" procedural framework that may arise when the same transaction gives rise to offences under both the PC-PNDT Act and general criminal law (IPC/BNS). In such cases:

The Appropriate Authority would investigate the PC-PNDT offence and file a complaint under Section 28;
The police could independently investigate any IPC/BNS offence arising from the same transaction (such as cheating, criminal conspiracy, or forgery) and file a chargesheet for those offences;
If police investigating an IPC/BNS offence discover material indicating a possible PC-PNDT violation, they must place that material before the Appropriate Authority for further action;
Conversely, if the Appropriate Authority finds material indicating an independent IPC/BNS offence, it should communicate that material to the police for independent investigation.

This "two-track" approach ensures that no offender escapes justice while respecting the statutory boundaries of each enforcement agency. It prevents the police from using the discovery of a general criminal offence as a pretext to investigate the specialised PC-PNDT offence, while also ensuring that the Appropriate Authority does not withhold evidence of general crimes from the police.

11Practical Implications & Future Impact

The Supreme Court's judgment in State of Uttar Pradesh v. Brij Pal Singh carries far-reaching implications for multiple stakeholders. The ruling fundamentally alters how PC-PNDT cases will be initiated, investigated, and prosecuted across India.

11.1 For Law Enforcement Agencies

Police departments across India must immediately revise their standard operating procedures. Station House Officers must be trained to refuse registration of FIRs for standalone PC-PNDT offences and to redirect complainants to the Appropriate Authority. Police personnel must understand that their role is now strictly supplemental and that any investigation they conduct independently will be legally futile. This requires significant attitudinal change, particularly in states where police have traditionally taken the lead in PC-PNDT enforcement.

11.2 For Appropriate Authorities

The judgment places enormous responsibility on Appropriate Authorities at the district and state levels. These bodies must now gear up to handle the entire spectrum of investigation — from receiving complaints, conducting decoy operations, gathering technical evidence, to filing complaints before Magistrates. Authorities must ensure they have adequate medical experts, legal officers, and investigative staff to discharge this responsibility effectively. The judgment implicitly demands greater budgetary allocation and administrative support for these Authorities.

11.3 For the Judiciary

Magistrates must now scrutinise the source of every PC-PNDT complaint before taking cognizance. If a chargesheet filed by the police comes before a Magistrate, it must be returned or rejected unless it is accompanied by a valid complaint under Section 28. This requires judicial training and the issuance of practice directions by High Courts to ensure uniform compliance.

11.4 For Medical Professionals

For doctors, radiologists, and genetic counsellors, the judgment offers procedural protection against arbitrary police action. Medical professionals accused of PC-PNDT violations will now be investigated by peers who understand the technical nuances of medical practice, rather than by police officers who may lack medical literacy. However, this protection comes with the understanding that the Appropriate Authority is equally empowered — and now solely empowered — to take stringent action.

11.5 For Pending Cases

The judgment raises important questions about pending cases across India where FIRs have been registered and chargesheets filed by the police. Accused persons in such cases may now move for quashing of proceedings on the ground that cognizance was taken on an invalid chargesheet. This could lead to a wave of litigation, though the Supreme Court has clarified that the judgment does not automatically invalidate past convictions where the trial has already concluded.

12Comparative Analysis: Special vs. General Law

The judgment in Brij Pal Singh is a masterclass in the interpretation of special statutes and their relationship with general criminal procedure. It reinforces several foundational principles of Indian jurisprudence:

Principle	Application in Brij Pal Singh	General Criminal Law Context
Special Law Prevails	PC-PNDT Act's special complaint mechanism (Section 28) overrides BNSS general FIR procedure	General principle: Generalia specialibus non derogant
Harmonious Construction	Section 27 (cognizable) and Section 28 (complaint-only) read together to avoid conflict	Statutes must be read as a coherent whole, not in isolation
Purpose-Based Interpretation	Socially beneficial nature of Act supports specialised enforcement by expert Authority	Beneficial legislation interpreted liberally to advance legislative intent
Avoiding Absurdity	Police investigation would be futile if chargesheet cannot lead to cognizance	Courts reject interpretations that create procedural impossibilities
Expressio Unius	Parliament expressly applied CrPC to searches (Section 30) but not to investigation	Express inclusion of one thing implies exclusion of others

The judgment also draws parallels with other special legislations where dedicated authorities have been created to enforce domain-specific laws. For example, the Enforcement Directorate investigates money laundering under the PMLA, the Serious Fraud Investigation Office (SFIO) handles corporate frauds under the Companies Act, and cybercrime cells investigate digital offences. In each case, the special agency's expertise is considered essential for effective enforcement. The PC-PNDT Act's Appropriate Authority serves the same function in the medical-legal domain.

For those interested in how special investigative mechanisms interact with general criminal law, our article on BNSS vs CrPC: Major Changes Explained provides valuable comparative insights into India's evolving criminal procedure framework.

13Conclusion & Key Takeaways

The Supreme Court's judgment in The State of Uttar Pradesh v. Brij Pal Singh (2026) is a watershed moment in the enforcement of the PC-PNDT Act. By holding that police cannot register FIRs or conduct investigations for offences under this specialised legislation, the Court has reinforced the statutory scheme that Parliament deliberately created to combat female foeticide through expert, sensitive, and technically competent enforcement.

The judgment is a reminder that not all cognizable offences are equal in the eyes of the law. While the general criminal procedure provides a robust framework for ordinary crimes, specialised legislation dealing with technical subjects requires specialised enforcement. The Appropriate Authority, with its medical expertise and institutional mandate, is the proper vehicle for investigating PC-PNDT violations. The police, while essential for maintaining law and order and assisting in general criminal matters, must respect the statutory boundaries that Parliament has drawn.

For the millions of unborn girl children whose lives are threatened by sex-selective practices, this judgment ensures that enforcement will be conducted by those who understand the medical, ethical, and social dimensions of the problem. It prevents the mechanical application of general criminal procedure to a field that demands nuanced expertise. At the same time, it preserves the police's role in addressing general crimes that may accompany PC-PNDT violations, ensuring that no offender escapes justice through procedural loopholes.

Key Takeaways from the Judgment

Police cannot register FIRs for offences under the PC-PNDT Act, despite Section 27 classifying them as cognizable.
Police cannot conduct investigations as the main investigative authority; their role is strictly supplemental to the Appropriate Authority.
Magistrates cannot take cognizance on a police chargesheet; cognizance is permissible only on a complaint by the Appropriate Authority or a person who has given 15 days' notice.
The Appropriate Authority is the sole entity responsible for investigating complaints and initiating prosecutions under the Act.
The "Two-Track" framework allows parallel investigation of PC-PNDT offences by the Authority and general criminal offences by the police arising from the same transaction.
The judgment applies only to offences under the PC-PNDT Act and does not affect the police's power to investigate independent offences under the IPC/BNS.
Pending cases initiated through police FIRs may be vulnerable to quashing if cognizance was taken on an invalid chargesheet.
The ruling reinforces the principle that special statutes creating complete codes override general criminal procedure where there is a conflict.

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State of Uttar Pradesh v. Brij Pal Singh (2026)

Police Cannot Register FIR And Conduct Investigation For PC-PNDT Act Offences

Table of Contents

1Introduction: Why This Judgment Matters