1. EVIDENTIARY VALUE OF FIR
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2. What is FIR ?
FIR is per se not defined in the code of criminal procedure.
On reading section 154, it may be extracted that “A FIR means the information, by whomsoever given, to the officer in charge of a police station in relation to the commission of a cognizable offence and which is first in point of time and on the strength of which the investigation into that offence is commenced.
FIR is not an encyclopedia. It is only to set the law in motion. It need not elaborate but should contain necessary allegations to constitute cognizable offences

3. Evidentiary Value of FIR
Substantive
Conduct
Admission
Dying Declaration
Confession
Procedural
Contradiction
Corroborate

4. FIR & Conduct
Provision for conduct is given under section 8 of IEA. Basically it is referred to show the conduct of an accused or informant as to commission of an cognizable offence.
Points to be considered :-
1. Time of giving information
2. Conduct of informant
Gulshan Kumar v. State, 1993(2) Crimes 239 (Delhi), in which Court held that FIR can be used under section 8 to show and establish the conduct of an informant.

5. FIR & Admission
Any FIR which is lodged by an accused can be used against him. Section 25 of the Evidence Act and Section 162 of the Code of Criminal Procedure do not bar its admissibility. The report is an admission by the accused of certain facts which have a bearing on the question to be determined by the courts under Section 21 of the Evidence Act shall permit.
Paddi v. State of M.P., A.I.R S.C. , The Apex court held that Admission of an accused can be proved against him under the provision of Section 21 of IEA

6. FIR & Dying Declaration
FIR can be used as substantive evidence on the death of the informant if it relates to the cause of informant’s death or circumstances of the transaction resulting in informant’s death within the meaning of section 32(1) of Evidence Act. In other case, it cannot be used as substantive evidence.
Munnu Raja v. State of Madhya Pradesh, Munnu Raja and Chhuttan were tried by the Sessions Judge, Chhatarpur on the charge that at about 10 a.m. on April, 30th, they committed the murder of one Bahadur Singh. Two eye witnesses were turned hostile and learned Sessions Judge thought that it was unsafe to rely on their testimony. Learned judge was also not impressed by three dying declarations given by the deceased with the result, the appellants were acquitted by the Sessions Court. The State preferred appeal in the High Court of Madhya Pradesh, which was allowed by a Division Bench. Thereafter the appellants preferred appeal to the Supreme Court.

7. FIR & Confession
A non-confessional First Information Report lodged by the accused can be used against him to prove his admissions in regard to certain facts under Section 21 of Evidence Act. (Nisar Ali v. State ofU.P.)
Certain portion of confessional First Information Report lodged by the accused can be used against him if they lead to the discovery of a fact within the meaning of Section 27 of Evidence Act.

8. FIR and Section 145, 157 of Indian Evidence Act
It can be used to corroborate the maker under S. 157 of Evidence Act, but not to corroborate the other witnesses. Apex Court has gone so far to say that the prosecution case cannot be thrown out on the mere ground that if the first information report an altogether different version was given by its maker. This position has not, however been maintained in toto in subsequent cases of the apex court
Section 145 talks about Cross- examination as to previous statement in writing. F.I.R. can be used to cross examine the informant and for contradicting the maker of it. this is possible by relying on Section 145.
Krishna Kumar v. State, it was held that When the F.I.R. is clouded with suspicion as it was product of undue deliberation and consultation, then F.I.R. loses its corroboration value.

9. CONCLUSION
F.I.R. is not a substantive piece of evidence.( Purshottam K. Bharaiya v. State of Gujarat)
It can only be used to corroborate the statement of the maker under Section 157, Evidence Act or to contradict it under Section 145 of the Evidence Act.( Bir Singh v. State of H.P.)
It can only be used for corroboration or contradiction purposes that too when F.I.R. was lodged by a person having direct knowledge about the occurrence.
The value of F.I.R. must always depend on the facts and circumstances of a given case (Dharma Rama Bhargava v. State of Maharashtra, 1973)

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