Framing of charges: conspiracy may be inferred from circumstantial evidence, and revision interference is limited at the charge stage.

At the stage of framing charges, interference in revision is unwarranted where the materials disclose sufficient grounds to proceed on triable offences. Criminal conspiracy need not be proved by direct evidence; it may be inferred from circumstantial evidence and the surrounding facts showing an agreement to pursue an unlawful design. Applying that standard, the Court found that the record, including the power of attorney and the steps taken in the sale transaction, supported the charges under Sections 409, 420 and 120B IPC. The challenge to the framing of charges therefore failed, and the accused were required to face trial.

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Issues: Whether the framing of charges under Sections 409, 420 and 120B of the Indian Penal Code, 1860 called for interference in revision, and whether the ingredients of criminal conspiracy could be inferred at the threshold stage.

Analysis: The material before the Court showed that the power of attorney was the central document and that the transaction of sale deeds had been acted upon through multiple steps. The Court reiterated that criminal conspiracy rests on an agreement to do an illegal act or to do a lawful act by illegal means, and that such agreement is seldom proved by direct evidence. It may be established by circumstantial evidence and the surrounding circumstances before, during and after the . At the stage of charge, the Court does not finally determine guilt; it only examines whether there are sufficient grounds to proceed. On the facts, the High Court was justified in holding that the material disclosed triable offences and that no interference was warranted.

Conclusion: The challenge to the framing of charges failed. The Court upheld the order declining interference and held that the appellants must face trial.

Final Conclusion: The appeal was rejected, and the prosecution was permitted to proceed on the charges framed, with the trial court asked to consider expeditious disposal and exemption requests in accordance with law.

Ratio Decidendi: At the stage of framing charges, interference is unwarranted where the materials disclose sufficient grounds to presume the commission of triable offences, and criminal conspiracy may be inferred from circumstantial evidence showing an agreement to pursue an unlawful design.

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