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Issues: Whether the High Court was justified in declining to examine the criminal revision on merits and whether, in the circumstances, the matter required reconsideration on the question of discharge.
Analysis: The scope of revisional interference against an order framing charge or refusing discharge is not barred merely because the order is not final; the High Court may intervene in an exceptional case to correct a patent jurisdictional error or to prevent abuse of process and secure the ends of justice. A discharge application cannot be treated as a mechanical formality, and the court must assess broad probabilities, the total effect of the material, and basic infirmities before deciding whether sufficient grounds exist to proceed. The High Court in the present case declined to examine the revision on merits and confined itself to jurisdiction, without testing the fairness of the investigation, the alleged improvements in witness statements, or the applicability of the settled principles governing discharge and revisional powers.
Conclusion: The High Court erred in refusing to consider the revision on merits, and the order was set aside with a direction to reconsider the matter afresh in accordance with law.
Ratio Decidendi: An order refusing discharge or framing charge may be interfered with in revision or under inherent jurisdiction in exceptional cases to prevent abuse of process or correct jurisdictional error, and the revisional court must examine the merits where the record discloses a plausible case for such scrutiny.