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Issues: Whether the revision petitions challenging rejection of discharge were liable to be allowed, and whether the materials in the charge-sheet disclosed only a matter for trial or were groundless so as to warrant discharge.
Analysis: The allegations against the petitioners, who were revenue officers, were that they had ordered mutation of land beyond the permissible extent and that such excess mutation occurred in collusion with the private developers and other accused persons involved in the land transactions. The Court applied the settled principles governing discharge under Sections 227, 239 and 240 of the Code of Criminal Procedure, 1973, namely that the court must sift the material only to see whether a prima facie case exists, that a detailed assessment of defence or a mini trial is impermissible, and that discharge is justified only when the charge is groundless or the materials disclose at best mere suspicion. The Court held that the charge-sheet contained material suggesting connivance and that the question whether the petitioners acted in concert with the other accused in ordering excess mutation was a matter for trial, not revisional interference.
Conclusion: The petitions for discharge were not maintainable on the materials before the Court, and the refusal to discharge the petitioners was upheld.