Summons on police report needs only prima facie satisfaction; revisional court cannot reappraise merits at the threshold.

When cognizance is taken on a police report under Section 190(1)(b) CrPC, the Magistrate need only be satisfied that sufficient grounds exist to proceed and is not required to record detailed reasons while issuing summons. At the summoning stage, the court does not assess sufficiency for conviction, weigh defence pleas, or conduct a detailed merits review. An order issuing summons is revisable under Section 397 CrPC as an intermediate or quasi-final order, but the revisional court cannot reappreciate the record like an appellate court or quash process by entering into merits at the threshold. The summons order was therefore restored.

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Issues: (i) Whether, when cognizance is taken on a police report under Section 190(1)(b) of the Code of Criminal Procedure, 1973, the Magistrate must record reasons while issuing process if satisfied that there are sufficient grounds for proceeding against the accused; (ii) Whether an order issuing summons is revisable under Section 397 of the Code of Criminal Procedure, 1973 and whether the High Court was justified in setting aside the Magistrate's order on merits.

Issue (i): Whether, when cognizance is taken on a police report under Section 190(1)(b) of the Code of Criminal Procedure, 1973, the Magistrate must record reasons while issuing process if satisfied that there are sufficient grounds for proceeding against the accused.

Analysis: For cognizance on a police report, the Magistrate is to examine the charge sheet and accompanying materials to see whether there is sufficient ground for proceeding. The requirement to briefly record reasons is attached to dismissal of a complaint or discharge at later stages, not to the mere issuance of process on a police report. At the summoning stage, the court need not assess sufficiency of evidence for conviction, weigh defence pleas, or undertake a detailed appraisal of merits.

Conclusion: The Magistrate was not required to record detailed reasons while issuing summons on the basis of the police report, and the order of issuance of process was valid.

Issue (ii): Whether an order issuing summons is revisable under Section 397 of the Code of Criminal Procedure, 1973 and whether the High Court was justified in setting aside the Magistrate's order on merits.

Analysis: An order issuing summons is not a purely interlocutory order but an intermediate or quasi-final order, so revisional jurisdiction under Section 397 is available. However, in exercising such jurisdiction, the High Court cannot reappreciate the materials as if in appeal or substitute its own view on the sufficiency of evidence at the nascent stage. The materials in the charge sheet, witness statements, bank transactions and call records furnished a prima facie basis to proceed, and the High Court erred in quashing the summons by entering into merits and possible defences.

Conclusion: The High Court was not justified in setting aside the Magistrate's order, and the revisional interference was erroneous.

Final Conclusion: The summons order based on the second supplementary charge sheet stood restored, and the prosecution was permitted to proceed before the trial court in accordance with law.

Ratio Decidendi: When cognizance is taken on a police report, issuance of summons requires only the Magistrate's satisfaction that there are sufficient grounds for proceeding, without a duty to record reasons or assess evidentiary sufficiency for conviction; such an order is revisable, but the revisional court cannot quash it by reappreciating the evidence at the summoning stage.

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