Inherent criminal jurisdiction cannot be used to bypass the bar on a second revision unless exceptional abuse of process is shown.

The HC noted that Section 482 CrPC preserves inherent power only to prevent abuse of process or secure the ends of justice, and cannot be used to bypass the express bar on a second revision under Section 397(3). Where a petition is, in substance, a second revision after revisional jurisdiction has already been exercised by the Sessions Judge, it is not maintainable unless rare and exceptional circumstances show grave miscarriage of justice or clear abuse of process. On the facts, no such exceptional circumstance was shown, so the challenge to the framing of charge failed and the criminal writ petition was dismissed, leaving the trial proceedings undisturbed.

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Issues: Whether a petition under Section 482 of the Code of Criminal Procedure, 1973 could be entertained when it was, in substance, a second revision barred by Section 397(3) of the Code.

Analysis: The statutory scheme bars a second revision by the same party after the Sessions Judge has already exercised revisional jurisdiction. The inherent power under Section 482 is preserved to prevent abuse of process or to secure the ends of justice, but it cannot be used to do indirectly what the Code expressly forbids directly. Such jurisdiction is reserved for rare and exceptional situations involving grave miscarriage of justice, failure of justice, or clear abuse of process. On the facts, no compelling or exceptional circumstance existed to justify bypassing the statutory bar.

Conclusion: The petition was not maintainable as a second revision disguised as an application under Section 482, and the challenge to the framing of charge failed.

Final Conclusion: The criminal writ petition was dismissed and the proceedings before the trial court were left undisturbed.

Ratio Decidendi: The inherent jurisdiction of the High Court under Section 482 of the Code of Criminal Procedure, 1973 cannot be invoked to circumvent the express statutory bar on a second revision under Section 397(3), except in rare cases involving abuse of process or failure of justice.

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