Criminal revision survives death of petitioner where fine affects the estate, allowing legal heir substitution and continuation.

In criminal revision, the petitioner's death does not automatically terminate the proceedings where no specific statutory bar applies. The High Court may permit substitution of a legal heir and continuation of the revision if the impugned sentence includes fine, because the liability can affect the deceased's estate and gives the heir a sufficient interest to prosecute the matter. The delay in seeking substitution was condoned on the explanation offered, including post-death circumstances and lockdown disruption, and the heir was brought on record so the revision could proceed on merits.

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Issues: Whether, on the death of the convicted applicant in a criminal revision, the proceedings abate and whether the legal heir can be brought on record and the revision continued, particularly where a sentence of fine affects the estate of the deceased.

Analysis: The revisional power under the Code of Criminal Procedure is discretionary and is exercised to secure the ends of justice. In the absence of a specific statutory bar for revision proceedings, the death of the petitioner does not necessarily terminate the revisional jurisdiction of the High Court. Where the impugned order includes a sentence of fine, the liability can affect the estate of the deceased, and the legal representative has a sufficient interest to seek continuation of the revision. The delay in moving the application was explained by the circumstances following the applicant's death and the disruptions caused by the lockdown, and the Court found no reason to refuse relief.

Conclusion: The application to condone delay was allowed, and the legal heir was permitted to be brought on record so that the criminal revision could be pursued on merits.

Ratio Decidendi: In criminal revision, the death of the petitioner does not automatically abate the proceedings, and the High Court may permit substitution and continuation where the sentence under challenge includes fine affecting the deceased's estate.

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