Inherent jurisdiction survives revisional remedy where quashing is sought to prevent abuse of process and secure justice.

The existence of a revisional remedy under the special enactment did not bar the High Court's inherent jurisdiction where quashing was sought to prevent abuse of process or secure the ends of justice, so the petition was treated as maintainable. The supplementary complaint and cognizance order also disclosed a prima facie basis for interim interference because the later complaint appeared to rely on material already recorded before the first complaint, with allegations substantially repeating earlier CBI material. The cognizance order was therefore stayed, while the merits were left for further consideration after pleadings.

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Issues: (i) Whether a petition under the inherent jurisdiction was maintainable despite the availability of revision under the special enactment; (ii) whether the supplementary prosecution complaint and the cognizance order disclosed a prima facie basis for interim interference.

Issue (i): Whether a petition under the inherent jurisdiction was maintainable despite the availability of revision under the special enactment.

Analysis: The special provision conferring appellate and revisional powers did not exclude the inherent powers of the High Court. The revisional power was confined to correcting legality, propriety, and jurisdictional errors, while the inherent jurisdiction remained available to prevent abuse of process and secure the ends of justice. The reliefs sought also extended beyond mere challenge to the cognizance order and included quashing of the supplementary complaint, which could be examined in inherent jurisdiction.

Conclusion: The petition was held to be maintainable under the inherent jurisdiction.

Issue (ii): Whether the supplementary prosecution complaint and the cognizance order disclosed a prima facie basis for interim interference.

Analysis: The supplementary complaint was filed after the original complaint, but the material relied upon appeared to consist of statements recorded before the first complaint rather than any clearly identified further evidence collected later. The Court also noted that the allegations in the supplementary complaint appeared to substantially repeat the language and substance of the earlier CBI material. In these circumstances, the cognizance order was found to have been passed without adequate advertence to the relevant factual and legal aspects, and the matter was considered fit for deeper examination after affidavits.

Conclusion: A prima facie case for interim interference was found, and operation of the cognizance order was stayed.

Final Conclusion: The petition was entertained on the inherent jurisdiction point and interim protection was granted, while the merits of the challenge were left for further consideration after pleadings.

Ratio Decidendi: The existence of a revisional remedy does not by itself bar the exercise of inherent jurisdiction where quashing is sought to prevent abuse of process or secure the ends of justice, and a summoning order must reflect application of mind to the facts and applicable law.

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