The term was first used in Justice Verma Committee Report in early 2013. Still not used in Code of Criminal Procedure as amended in early 2013 (April w.e.f. February) based upon this report.
Section 154 Cr.P.C. does not provide for any requirement of territorial jurisdiction for registering FIRs. So an FIR can be registered in any police station irrespective of territorial jurisdiction. But Section 156(1) Cr.P.C. provides for territorial jurisdiction by implication for conducting investigation by a police officer. So a zero FIR will be registered under Section 154 Cr.P.C. in case of the lack of territorial jurisdiction and then transferred to the concerned Police Station due to Section 156(1) Cr.P.C.
Ministry of Home Affairs, Government of India, Circular dated 10.05.2013 is on these lines.
Though Lalita Kumari judgement of Supreme Court passed in November, 2013 does not deal with the question of territorial jurisdiction of police stations in the matters of registering FIRs, it certainly deals with their duty to register an FIR when the information discloses the commission of a cognizable offence.
Thereafter another Circular has been issued by Ministry of Home Affairs, Government of India on 05.02.2014 on Zero FIRs and the duty of Police to register FIRs.
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