Public interest standing cannot be used to block a criminal investigation or short-circuit an FIR at the investigation stage.

Public interest standing cannot be used by a third party to obstruct a bona fide criminal investigation or to litigate on behalf of suspected accused persons; the petition seeking to restrain issuance of a letter rogatory, challenge the criminal revision, and quash the FIR was therefore held not maintainable. The High Court's revisional and inherent powers are intended to prevent abuse of process and secure justice, but they cannot ordinarily be invoked at the investigation stage to terminate an ongoing police inquiry or pre-judge whether the FIR discloses an offence. The Court therefore set aside the suo motu intervention and left the investigation to proceed in accordance with law.

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Issues: (i) whether a third party had locus standi to invoke public interest litigation to restrain issuance of a letter rogatory, challenge the criminal revision, and seek quashing of the FIR and investigation; (ii) whether the High Court could, at the investigation stage, suo motu exercise revisional and inherent powers to register a case in its own motion and to quash the FIR and connected proceedings.

Issue (i): Whether a third party had locus standi to invoke public interest litigation to restrain issuance of a letter rogatory, challenge the criminal revision, and seek quashing of the FIR and investigation.

Analysis: Public interest litigation is maintainable only where a bona fide public wrong or public injury is brought before the Court by a person having sufficient interest and not by a busybody, meddlesome interloper, or a litigant seeking to advance personal, political, or proxy interests. In criminal matters, the right to challenge investigative steps and the prosecution ordinarily belongs to the accused or a person legally entitled to do so. A third party cannot, under the label of public interest, seek to stall an investigation or to litigate on behalf of suspected accused persons.

Conclusion: The third party had no locus standi and the petition was not maintainable as public interest litigation.

Issue (ii): Whether the High Court could, at the investigation stage, suo motu exercise revisional and inherent powers to register a case in its own motion and to quash the FIR and connected proceedings.

Analysis: Revisional and inherent powers are meant to correct jurisdictional error, prevent abuse of process, and secure the ends of justice, but they cannot be used to short-circuit a legitimate police investigation or to pronounce in advance that an FIR discloses no offence when the investigation is still at a threshold stage. The statutory scheme preserves the investigative domain of the police and permits judicial interference only in exceptional cases. The High Court therefore exceeded the proper limits of its jurisdiction in taking suo motu cognizance and issuing show-cause notice for quashing the criminal proceedings.

Conclusion: The High Court could not validly assume suo motu jurisdiction to quash the FIR and investigation at that stage.

Final Conclusion: The decision upheld the objection to the maintainability of the third party proceedings, but set aside the High Court's suo motu intervention and preserved the criminal investigation to proceed in accordance with law.

Ratio Decidendi: Public interest standing cannot be invoked to advance the interests of suspected accused persons or to obstruct a bona fide criminal investigation, and the High Court's inherent or revisional powers cannot be used to terminate such investigation prematurely except in exceptional cases of clear abuse or illegality.

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