Upkar Singh vs Ved Prakash & Ors

The Supreme Court referred the case to a larger bench due to doubts regarding the correctness of the judgment in T.T. Antony vs. State of Kerala (2001) 6 SCC 181. The Court examined the implications of Section 156(3) of the Criminal Procedure Code, emphasizing that an aggrieved person can file a complaint before a Magistrate even if a police investigation is ongoing. The Court held that the dismissal of the appellant's revision petition by the High Court was not justified, thereby setting the stage for a re-evaluation of the legal principles established in prior judgments regarding the registration of cross FIRs.