The Supreme Court in the landmark case of Lalita Kumari
v. State of UP held that

Lalita Kumari v. State of UP – FIR mandatory in cognizable cases The writ petition has been filed in the Supreme Court under Article 32 of the Constitution by Lalita Kumari (minor) through her father for the issuance of a writ of Habeas Corpus or directions of like nature for the protection of his daughter who has been kidnapped.   The hon'ble Supreme Court gave various directions- It is mandatory to register an FIR u/s 154 of the Code, if the information discloses the commission of a cognizable offence and no preliminary inquiry is permissible in such a situation. If the information does not disclose a cognizable offence but indicates the necessity for an inquiry, a preliminary inquiry may be conducted to ascertain whether information reveals any cognizable offence.