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Issues: Whether, after the petitioner had already invoked the revisional jurisdiction of the Sessions Court and failed, the High Court should exercise its inherent jurisdiction under Section 482 of the Code of Criminal Procedure, 1973 to interfere with the orders declining police investigation under Section 156(3) and proceeding with the complaint case.
Analysis: The bar against a second revision under Section 397(3) of the Code of Criminal Procedure, 1973 does not wholly exclude the High Court's inherent power under Section 482, but that power is to be exercised sparingly and with great caution. Interference is justified only where there is abuse of the process of court, serious miscarriage of justice, non-compliance with mandatory provisions, or an apparent mistake by the revisional court. On the facts, the complaint disclosed material within the complainant's reach, the Magistrate had declined investigation under Section 156(3) and taken cognizance under Section 200, and the revisional court had affirmed that approach. No special case was shown to warrant extraordinary interference.
Conclusion: The petition under Section 482 was not maintainable on the facts as a substitute for a barred second revision, and the High Court declined to interfere.