Inherent jurisdiction cannot replace a second revision in cheque dishonour cases; defences must be raised before the trial court.

Inherent jurisdiction cannot be used as a substitute for a second revision after a statutory remedy has already been exhausted, and it will be invoked only to prevent abuse of process or miscarriage of justice. In a cheque dishonour prosecution, a demand notice is to be read as a whole; where the cheque details and dishonour are sufficiently disclosed, no interference is warranted. Defences that depend on evidence cannot be tested at the quashing stage, because the accused must place them before the trial court under the Negotiable Instruments Act's special procedure, including the scope for recall of witnesses and defence evidence. No ground was made out to quash the complaint or summoning proceedings.

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Issues: Whether a petition under the inherent jurisdiction could be entertained after the petitioners had already pursued a revision, and whether the complaint and summoning process in the dishonoured cheque prosecution disclosed any ground for interference.

Analysis: The statutory bar against a further revision after one remedy had been exhausted required the inherent power to be used sparingly and only to prevent abuse of process or miscarriage of justice. The challenge to the demand notice was rejected because the notice had to be read as a whole and the cheque details and dishonour were sufficiently disclosed. The defence raised by the petitioners depended on evidence and could not be examined in proceedings under the inherent jurisdiction. In prosecutions under the Negotiable Instruments Act, the accused is required to place his defence before the trial court, and the scheme of the Act permits the trial court to consider recall of witnesses and defence evidence in accordance with the special procedure.

Conclusion: The petitioners were not entitled to invoke the inherent jurisdiction as a substitute for a second revision, and no ground was made out for quashing the complaint or the summoning proceedings. The challenge failed.

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