Section 154 of the Cr.P.C. is related to lodging of FIR. This section or any other section of the Cr.P.C. does not prescribe any time limit within which FIR should be lodged. Delay in lodging FIR depends on various factors of the case. If the satisfactory explanation will be given by the prosecution for the cause of delay then it will not be fatal for the prosecution. If satisfactory explanation will not be given by the prosecution for the delay then the benefit of delay will go to the accused.
It is well-settled that the delay in giving the FIR by itself cannot be a ground to doubt the prosecution case. Knowing the Indian conditions as they are we cannot expect these villagers to rush to the police station immediately after the occurrence. Human nature as it is, the kith and kin who have witnessed the occurrence cannot be expected to act mechanically with all the promptitude in giving the report to the police. At times being grief-stricken because of the calamity it may not immediately occur to them that they should give a report. After all it is but natural in these circumstances for them to take some time to go to the police station for giving the” report…..Tara Singh And Others vs The State Of Punjab, AIR 1991 SC 63.
There is no hard and fast rule that any delay in lodging the FIR would automatically render the prosecution case doubtful. It necessarily depends upon facts and circumstances of each case whether there has been any such delay in lodging the FIR which may cast doubt about the veracity of the prosecution case and for this a host of circumstances like the condition of the first informant, the nature of injuries sustained, the number of victims, the efforts made to provide medical aid to them, the distance of the hospital and the police station, etc. have to be taken into consideration. There is no mathematical formula by which an inference may be drawn either way merely on account of delay in lodging of the FIR.. Amar Singh vs Balwinder Singh & Ors, (2003) 2 SCC 518.