Rajinder Singh Katoch vs Chandigarh Administration & Ors

The Supreme Court held that the right of a co-sharer to enjoy joint family property is a civil right, and criminal proceedings cannot be initiated to enforce such rights. The Court emphasized that under Section 154 of the Code of Criminal Procedure, police officers are required to register a First Information Report (FIR) only if the allegations disclose a cognizable offence, but they may conduct a preliminary inquiry to ascertain the substance of the complaint. In this case, the Court upheld the lower court's decision, finding that the appellant's allegations were false and motivated by an ulterior motive to gain illegal possession of the property.