The judgment in Lalita Kumari v. State of Uttar Pradesh & Ors., (2014) 2 SCC 1, occupies a seminal position in the annals of Indian jurisprudence. The verdict profoundly redefined the obligations of law enforcement agencies in the registration of First Information Reports (FIRs). This case underscores the principle of nullum tempus occurit regi (time does not run against the Crown) and introduced the concept of "Zero FIR," enabling access to justice irrespective of territorial jurisdiction. This article elucidates the legislative underpinnings, constitutional guarantees, and judicial pronouncements integral to this landmark ruling, juxtaposed with Section 173(1) of the Bharatiya Nagrik Suraksha Sanhita, 2023 (BNSS), and its corollaries.

Introduction
The pivotal role of an FIR lies at the genesis of the criminal justice process. Prior to Lalita Kumari, the registration of FIRs was fraught with ambiguities and inconsistencies, with law enforcement often exercising discretionary authority, thereby compromising the victim's access to justice. The Supreme Court, in its sagacious adjudication in Lalita Kumari, rendered a clarion call to uphold the statutory mandate of Section 154 of the Code of Criminal Procedure, 1973 (now re-enacted under Section 173 of the BNSS, 2023). This judgment bridged the lacunae in procedural law, affirming that the registration of an FIR is not merely a procedural formality but a substantive right of the complainant.

Case Background
The petitioner, Lalita Kumari, a minor, was allegedly kidnapped. Despite her father's repeated attempts to lodge a complaint, the police dilly-dallied, ostensibly conducting a "preliminary inquiry" before registering the FIR. This blatant apathy on the part of law enforcement culminated in the Supreme Court suo motu entertaining the matter to examine the larger issue of whether the registration of an FIR is mandatory upon the disclosure of a cognizable offence.

Legal Framework
Relevant Constitutional Provisions

• Article 21: Enshrining the right to life and personal liberty, the apex court emphasized that access to justice is a sine qua non for ensuring the sanctity of Article 21. Arbitrary delays in FIR registration infringe upon this fundamental right.
• Article 14: The court reiterated the principle of equality before law, mandating uniform application of the procedural safeguards irrespective of socio-economic or geographical disparities.

Statutory Provisions

• Section 154, CrPC (now Section 173, BNSS, 2023): This provision obligates the police to register an FIR upon receiving information about the commission of a cognizable offence.
• Section 173(1), BNSS, 2023: Under the Bharatiya Nagrik Suraksha Sanhita, 2023, the concept of "Zero FIR" was codified, enabling individuals to lodge FIRs in any police station, irrespective of jurisdiction.

Judicial Precedents

• State of Haryana v. Bhajan Lal (1992 Supp (1) SCC 335): Enumerated exceptional circumstances where police could refrain from registering an FIR.
• Ramesh Kumari v. State (NCT of Delhi) ((2006) 2 SCC 677): Reaffirmed that police have a statutory obligation to register an FIR upon disclosure of a cognizable offence.

Judgment and Reasoning
Mandatory Nature of FIR Registration
The Supreme Court, in a unanimous verdict, held that the police are bound to register an FIR upon receiving information regarding a cognizable offence. The court categorically rejected the practice of conducting a "preliminary inquiry" before FIR registration, as it obfuscates justice and delays the investigative process.

Zero FIR and Territorial Jurisdiction
The concept of "Zero FIR" emerged as a corollary to the court's dictum, ensuring that an FIR can be filed at any police station, irrespective of territorial jurisdiction. The receiving police station is mandated to transfer the FIR to the jurisdictionally competent police station under Section 173(1) of BNSS, thereby obliterating geographical impediments to justice delivery.

Preliminary Inquiry
The court delineated instances where a preliminary inquiry is permissible, such as matrimonial disputes, commercial offences, and medical negligence cases. However, it emphasized that such inquiries must not exceed a reasonable time frame, as prescribed by Section 173 of BNSS.

Impact and Analysis
The judgment served as a harbinger of procedural reforms in the criminal justice system. By mandating the registration of FIRs, the court fortified the rights of victims, ensuring timely intervention in cognizable offences. The institutionalization of "Zero FIR" eliminated jurisdictional dilemmas, expediting access to justice.

The decision also has significant implications under the Bharatiya Nagrik Suraksha Sanhita, 2023, which incorporated these principles legislatively. However, operational challenges persist, including resource constraints and lack of police accountability mechanisms, necessitating systemic reforms.

Criticism and Controversies
While the judgment is laudable for its victim-centric approach, critics argue that mandatory FIR registration may result in frivolous complaints, burdening the already overstretched police machinery. Furthermore, the discretion allowed in preliminary inquiries may lead to arbitrary interpretations, undermining the uniformity envisioned by the judgment.

Conclusion
The Lalita Kumari verdict embodies the judiciary's proactive role in safeguarding constitutional rights against executive inertia. By institutionalizing "Zero FIR" and streamlining procedural mandates, the Supreme Court ensured that the criminal justice system remains accessible, equitable, and efficacious. Nonetheless, the practical efficacy of these measures hinges on robust implementation and accountability frameworks.

This landmark decision, interwoven with statutory developments under the BNSS, serves as a testament to the judiciary's commitment to justice and equity, reiterating that the scales of justice must never tilt against the aggrieved.