A telephonic information received at the police station need not, in all circumstances, be deemed to be the First Information. When no formal investigation is commenced upon such information, it cannot be held to be an information under Section 154 of the Criminal Procedure Code, and a statement recorded by the police until they commence investigation does not attract Section 162 of the Criminal Procedure Code. Every telephonic information about the commission of a cognizable offence, irrespective of the nature and details of such information, cannot be treated as an FIR.

If a telephonic message is an extremely cryptic one, it could not be regarded as an FIR. When a person conveying the information did not disclose his identity, nor did he give any other particulars, and all that was conveyed was that firing had taken place at the taxi stand in Ludhiana, this cryptic and anonymous oral message, which did not clearly specify a cognizable offence, cannot be treated as a First Information Report.

It can be treated as an FIR only if, based on this information, the in-charge of the police station is satisfied about the commission of a cognizable offence and proceeds from the police station after recording such information and starts the investigation.

Where the investigation commenced on receipt of telephonic information about the crime, statements given subsequently furnishing detailed particulars of the accused are hit by Section 162 CrPC. When an officer in charge of the police station received a telephonic message from a Head Constable regarding the commission of a cognizable offence and directed the Head Constable to proceed to the spot and do the needful, and subsequently lodged a complaint about the incident, the information given by the Head Constable was the first information within the meaning of Section 154, which led to action being taken by the police. The complaint received and registered later would be hit by Section 162 and would be inadmissible in evidence.