Section 160 CrPC applies only to witnesses, not accused persons, and revision cannot pre-empt trial findings.

Section 160 CrPC applies only to witnesses or persons likely to be acquainted with the facts of the case, so it cannot be used to compel an accused person's attendance at a police station for questioning. The provision also does not justify a general rule confining women to questioning at their residences or only by women police officers. The revisional court likewise exceeded its limited role by recording premature findings on confession, recovery, compensation, and departmental action before investigation and trial were completed; such matters were reserved for trial and further investigation. The impugned revision order was therefore set aside.

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Issues: (i) Whether Section 160 of the Code of Criminal Procedure authorises summoning of an accused person for attendance at a police station during investigation and permits directions confining women to be questioned only at their residences or by women police officers; (ii) Whether the High Court was justified in recording findings on the evidentiary value of confession and recovery, awarding compensation, and issuing departmental directions at the revision stage before completion of investigation and trial.

Issue (i): Whether Section 160 of the Code of Criminal Procedure authorises summoning of an accused person for attendance at a police station during investigation and permits directions confining women to be questioned only at their residences or by women police officers.

Analysis: Section 160 is directed to persons who appear to be acquainted with the facts of the case and are to be examined as witnesses. It is not meant to secure the attendance of an accused person for answering the charge against him. The provision is a facility for obtaining evidence during investigation and does not enlarge into a power to treat the accused as a witness. By extending its scope and directing a special procedure for women accused/witnesses as a general mandate, the High Court acted contrary to the statutory scheme and the needs of effective investigation.

Conclusion: The direction treating accused persons as falling within Section 160 and requiring the impugned circular-based procedure was unsustainable and was set aside.

Issue (ii): Whether the High Court was justified in recording findings on the evidentiary value of confession and recovery, awarding compensation, and issuing departmental directions at the revision stage before completion of investigation and trial.

Analysis: The High Court went beyond the limited scope of revision by treating matters that required full trial, including the value of confession and recovery, as concluded against the prosecution. Such findings foreclosed further investigation and were incompatible with the stage contemplated by Section 173(2) of the Code of Criminal Procedure. The award of compensation and directions for immediate departmental action were also founded on assumptions that should not have been finally adjudicated before trial, and the criminal revision had in any event become infructuous to the extent it sought to undo an order already acted upon.

Conclusion: The findings, compensation order, and departmental directions were set aside as impermissible at that stage.

Final Conclusion: The criminal appeal succeeded, the judgment of the High Court was overturned, and the impugned revision order was quashed in full.

Ratio Decidendi: Section 160 of the Code of Criminal Procedure applies only to witnesses or possible witnesses and cannot be used to compel attendance of an accused person, while a revisional court cannot record premature findings that stifle investigation or decide matters reserved for trial.

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