Prima facie process inquiry under criminal procedure must rest on complaint material alone; defence material cannot guide revision.

At the stage of inquiry under Section 202 and issuance of process under Section 204 of the Code of Criminal Procedure, the Magistrate must confine consideration to the complaint and the evidence supporting it to determine whether a prima facie case exists. Materials produced by the accused are not within the permissible field of inquiry at that stage. Revisional review is similarly limited and cannot be used to reappreciate the merits or substitute the High Court's view for the Magistrate's discretion. Interference is justified only where no offence is disclosed, the allegations are inherently improbable, the discretion is arbitrary or based on irrelevant material, or there is a fundamental legal defect.

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Issues: Whether, at the stage of inquiry under Section 202 of the Code of Criminal Procedure and issuance of process under Section 204 of the Code of Criminal Procedure, the Magistrate can look beyond the complaint and the evidence produced in support of it by considering materials produced by the accused, and whether the High Court in revision can interfere with an order issuing process on a reappreciation of the merits.

Analysis: The scope of inquiry under Section 202 is confined to ascertaining whether, on the complaint and the supporting material, there is sufficient ground for proceeding and a prima facie case for issuance of process. The accused has no locus standi at that stage and materials produced by the accused are outside the permissible field of consideration. Revisional interference is equally narrow and is not meant for substituting the High Court's own view on the merits of the allegations for the judicial discretion exercised by the Magistrate. Interference is justified only where the complaint discloses no offence, the allegations are inherently improbable, the discretion is arbitrary or based on irrelevant material, or there is a fundamental legal defect.

Conclusion: The Magistrate acted within jurisdiction in issuing process on the basis of the complaint and supporting evidence, and the High Court erred in quashing that order by considering inadmissible defence material and reappraising the merits.

Ratio Decidendi: At the stage of inquiry under Section 202 and issuance of process under Section 204 of the Code of Criminal Procedure, the Magistrate must confine himself to the complaint and the supporting evidence to see whether a prima facie case exists, and the High Court cannot in revision reassess the merits by relying on defence material or substituting its own discretion for that of the Magistrate.

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