Locus standi in criminal investigation barred a stranger from using public interest and inherent powers to halt proceedings.

A stranger to a criminal prosecution cannot maintain a public interest petition or invoke revisional or inherent criminal jurisdiction to challenge a pending investigation, seek restraint on a letter rogatory, or ask for quashing of the FIR. The Court held that such objections belong to persons directly affected and that the petitioner's lack of locus standi rendered the proceeding non-maintainable. Because the main petition was incompetent, the interveners had no independent right to be impleaded. The High Court's attempt to take suo motu criminal cognizance on that basis and issue notice was unsustainable, though the investigation and related proceedings were left to continue.

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Issues: (i) whether a third party could maintain a public interest petition and invoke revisional or inherent criminal jurisdiction to challenge a pending investigation and request restraint on issuance of a letter rogatory; (ii) whether interveners had a right to be impleaded in such proceedings; (iii) whether the High Court could, on the petitioner's application, take suo motu cognizance and issue notice to quash the FIR and proceedings.

Issue (i): whether a third party could maintain a public interest petition and invoke revisional or inherent criminal jurisdiction to challenge a pending investigation and request restraint on issuance of a letter rogatory.

Analysis: The proceedings arose out of a criminal investigation against named accused persons. The challenge was not by any accused but by a stranger to the criminal case claiming public interest. The Court held that questions relating to the legality of the investigation, the FIR, and the steps taken in aid of investigation are matters for the persons directly affected to raise at the appropriate stage. A third party cannot, under the guise of public interest, invoke criminal revisional or inherent jurisdiction to stall the investigation or seek quashing of the FIR.

Conclusion: The petitioner's lack of locus standi was affirmed, and the public interest petition was not maintainable.

Issue (ii): whether interveners had a right to be impleaded in such proceedings.

Analysis: Once the original petition itself was found to be incompetent for want of locus standi, the interveners could claim no independent right to participate as if they were parties entitled to contest the criminal proceedings. Their applications stood on no firmer footing than the main petition and could not be sustained.

Conclusion: The intervention and impleadment claims were rejected.

Issue (iii): whether the High Court could, on the petitioner's application, take suo motu cognizance and issue notice to quash the FIR and proceedings.

Analysis: The High Court's assumption of suo motu criminal jurisdiction on the basis of a petition found to be non-maintainable was held to be unsustainable. The Court held that such a course could not be founded on strained reasoning and could not be used to issue notice for quashing proceedings initiated on the FIR. However, the underlying investigation and the letter rogatory already issued were not disturbed.

Conclusion: The suo motu cognizance and show-cause notice were set aside, while the criminal proceedings pursuant to the FIR were left unaffected.

Final Conclusion: The Court upheld the dismissal of the public interest revision and the rejection of intervention, set aside the High Court's suo motu notice, and allowed the criminal investigation and related proceedings to continue in accordance with law.

Ratio Decidendi: A stranger to a criminal prosecution has no locus standi to invoke public interest litigation, revisional jurisdiction, or inherent criminal powers to interfere with investigation or seek quashing of the FIR, and such proceedings cannot be the basis for valid suo motu criminal cognizance.

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