Interlocutory charge orders do not bar inherent quashing power, while Article 227 cannot ordinarily be used to interfere.

An order framing charge or issuing process is interlocutory because it only formulates the accusation and does not finally determine the parties' rights or terminate the criminal proceeding. The bar on revision against interlocutory orders under section 397(2) does not, by itself, oust the High Court's separate inherent power under section 482, which may still be used in an appropriate case to prevent abuse of process and secure the ends of justice. Supervisory jurisdiction under Article 227 is limited to keeping subordinate courts within jurisdiction and cannot ordinarily be invoked to reappraise or interfere with such threshold criminal orders.

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Issues: (i) Whether an order framing a charge or issuing process against an accused is an interlocutory order or a final order; (ii) whether the bar under section 397(2) of the Code of Criminal Procedure, 1973, excludes the High Court's inherent power under section 482 to quash such an order or proceeding; (iii) whether Article 227 of the Constitution of India can be invoked to interfere with such orders.

Issue (i): Whether an order framing a charge or issuing process against an accused is an interlocutory order or a final order.

Analysis: An order is final only if it determines the principal matter in dispute or finally disposes of the rights of the parties. Framing of charge and issuance of process merely formulate the accusation and require the accused to face trial; they do not terminate the proceedings or decide the dispute finally. Such orders are procedural steps taken at the threshold of the criminal process and leave the merits to be adjudicated on evidence.

Conclusion: The order framing a charge or issuing process is an interlocutory order, not a final order.

Issue (ii): Whether the bar under section 397(2) of the Code of Criminal Procedure, 1973, excludes the High Court's inherent power under section 482 to quash such an order or proceeding.

Analysis: The revisional bar in section 397(2) applies to interlocutory orders in revision, but the inherent power preserved by section 482 is a separate jurisdiction meant to prevent abuse of process and secure the ends of justice. That power is not created by the Code but preserved by it, and its exercise is not ousted unless the statute clearly says so. In a suitable case where no case is made out and continuance of the proceeding would amount to abuse of process, the High Court may quash the charge or process notwithstanding section 397(2).

Conclusion: The bar under section 397(2) does not, by itself, exclude the High Court's inherent power under section 482 to quash an interlocutory order or proceeding in an appropriate case.

Issue (iii): Whether Article 227 of the Constitution of India can be invoked to interfere with such orders.

Analysis: Supervisory jurisdiction under Article 227 is limited to ensuring that subordinate courts act within the bounds of their authority. It is not a power to correct mere errors of fact or to reappraise the merits of an interlocutory order such as framing of charge or issue of process. Relief against such orders cannot ordinarily be founded on Article 227.

Conclusion: Article 227 cannot be invoked to interfere with the framing of charge or issuance of process in the manner sought.

Final Conclusion: The criminal process orders were held to be interlocutory, yet the High Court retained inherent power to quash them in a proper case to prevent abuse of process and secure the ends of justice, while supervisory interference under Article 227 was not available for that purpose.

Ratio Decidendi: The revisional bar against interlocutory orders does not curtail the High Court's separate inherent jurisdiction to quash criminal proceedings where intervention is necessary to prevent abuse of process or to secure the ends of justice.

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