Inherent jurisdiction under Section 482 CrPC cannot bypass the bar on second revision absent exceptional circumstances.

Section 482 CrPC is discussed as an exceptional inherent power that cannot be used to bypass the statutory bar on a second revision under section 397(3) merely by changing the form of the proceeding. The commentary states that such jurisdiction is confined to cases of grave miscarriage of justice, abuse of process, failure of justice, or clear procedural non-compliance, and was not available on the facts described. It also explains that a complaint alleging non-compliance with debenture-related prospectus conditions under the Companies Act, 1956 disclosed a prima facie case, and objections based on locus standi or lack of jurisdiction did not justify quashing at the threshold.

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Issues: (i) Whether the petitioners could invoke the inherent jurisdiction again after having already pursued revision against the same order in view of the bar under section 397(3) of the Criminal Procedure Code, 1973. (ii) Whether the complaint and the orders of the courts below warranted quashing under section 482 of the Criminal Procedure Code, 1973 on the grounds of lack of jurisdiction, want of locus standi, or absence of any prima facie offence under the Companies Act, 1956.

Issue (i): Whether the petitioners could invoke the inherent jurisdiction again after having already pursued revision against the same order in view of the bar under section 397(3) of the Criminal Procedure Code, 1973.

Analysis: The earlier revisional remedy had already been exhausted against the trial court's order. The inherent power under section 482 is preserved to prevent abuse of process and to secure the ends of justice, but it cannot be used to defeat the statutory bar on a second revision merely by changing the label of the proceeding. That power is available only in exceptional cases where there is grave miscarriage of justice, abuse of process, failure of justice, or non-compliance with statutory procedure.

Conclusion: The petitioners could not use section 482 of the Criminal Procedure Code, 1973 to circumvent the bar created by section 397(3) in the absence of exceptional circumstances.

Issue (ii): Whether the complaint and the orders of the courts below warranted quashing under section 482 of the Criminal Procedure Code, 1973 on the grounds of lack of jurisdiction, want of locus standi, or absence of any prima facie offence under the Companies Act, 1956.

Analysis: The complaint disclosed allegations that the prospectus conditions relating to debentures were not honoured and that the conduct complained of attracted the provisions of the Companies Act, 1956. The courts below had considered the objections in detail and found that the matter disclosed a prima facie case for trial. The contention that the complainant lacked standing was also repelled, as the matter could not be quashed at the threshold merely on that ground. No material was found to show grave injustice, abuse of process, or a jurisdictional defect calling for interference at the inherent stage.

Conclusion: The complaint was not liable to be quashed and the orders of the courts below were sustained.

Final Conclusion: The inherent jurisdiction was declined, and the complaint was permitted to proceed to trial without interference from the High Court.

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