Revisional remedy against process orders bars Section 482 invocation where a specific statutory challenge remains available.

An application under Section 482 CrPC to quash process issued under Section 406 IPC was considered inappropriate where a revision before the Sessions Court provided an efficacious statutory remedy. The material noted that an order issuing process is not purely interlocutory, because success in challenging it would terminate the criminal proceedings, and therefore revisional jurisdiction under Section 397 is available. It also distinguished the Magistrate's power to recall process from the separate question of revisional maintainability. On this analysis, inherent powers were not to be invoked when a specific and effective remedy existed, and the applicants were directed to pursue revision before the Sessions Court.

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Issues: Whether an application under Section 482 of the Code of Criminal Procedure, 1973 for quashing process issued under Section 406 of the Indian Penal Code, 1860 was maintainable when a revision before the Sessions Court was an efficacious remedy and whether the order issuing process was interlocutory in nature.

Analysis: The availability of inherent jurisdiction under Section 482 is ordinarily excluded where the Code provides a specific remedy. The decisions considered showed that an order issuing process is not merely interlocutory, because if the challenge succeeds the criminal proceedings themselves would terminate. The judgments relied upon also showed that the question of recall of process by the Magistrate was distinct from the question whether a revision before the Sessions Court lies against the process order. On the authorities examined, the revisional remedy under Section 397 is available against an order issuing process, and the bar against interference in interlocutory matters does not apply. Since a specific and effective statutory remedy existed, invocation of inherent powers was not appropriate.

Conclusion: The application under Section 482 was not entertained, and the applicants were left to pursue revision before the Sessions Court.

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