Here’s the judgment that shows that a delay in filing an FIR can be seen as an abuse of court process.
Here’s the paragraph of relevance:
9. Prompt and early reporting of the occurrence by the informant with all its vivid details gives an assurance regarding its true version. In case, there is some delay in filing the FIR, the complainant must give explanation for the same. Undoubtedly, delay in lodging the FIR does not make the complainant’s case improbable when such delay is properly explained. However, deliberate delay in lodging the complaint may prove to be fatal. In such case of delay, it also cannot be presumed that the allegations were an after thought or had given a coloured version of events. The court has to carefully examine the facts before it, for the reason, that the complainant party may initiate criminal proceedings just to harass the other side with mala fide intentions or with ulterior motive of wreaking vengeance. The court proceedings ought not to be permitted to degenerate into a weapon of harassment and persecution. In such a case, where an FIR is lodged clearly with a view to spite the other party because of a private and personal grudge and to enmesh the other party in long and arduous criminal proceedings, the court may take a view that it amounts to an abuse of the process of law. (Vide: Sahib Singh v. State of Haryana, AIR 1997 SC 3247; G. Sagar Suri; Anr. v. State of U.P.; Ors., AIR 2000 SC 754; Gorige Pentaiah v. State of A.P.; Ors., (2008) 12 SCC 531; and Kishan Singh (dead) thr. Lrs. v. Gurpal Singh ; Ors., AIR 2010 SC 3624)