In Shashikant v. Central Bureau of Investigation & Ors.

, It was held that preliminary

inquiry is necessary on the basis of anonymous Complaint. In this case, an anonymous
complaint asserted the corrupt practice of Special Police Force was received. Authorities can
perform preliminary inquiry on the said complaint. Under section 125 of the Code, when a
report filed is cognizable offence, a FIR should be lodged, to carry out a preliminary inquiry
even under the Code is not unknown. In case were anonymous complaint is received then no
investigation will be carried immediately thereupon. When a FIR is lodged, the officer in
charge of the police station is statutorily liable to inform Magistrate the same. It also states
that if there is no sufficient ground for entering into investigation then Investigation Officer
should not investigate. Therefore, this situation differs from facts and circumstances of each
case.