Inherent criminal jurisdiction cannot bypass an available revisional remedy unless exceptional circumstances justify intervention.

Where an impugned order is revisable under Section 397 CrPC, a petition under Section 482 CrPC is not maintainable unless extraordinary circumstances are shown to prevent abuse of process or secure the ends of justice. The High Court treated the revisional remedy as the appropriate statutory course and held that the inherent power under Section 482 is residuary, extraordinary, and to be exercised sparingly. On the facts pleaded, no specific material established any exceptional circumstance justifying bypass of the revisional remedy, and a bare assertion of territorial jurisdiction did not suffice. The petition was therefore held not maintainable and the petitioners were relegated to revision.

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Issues: Whether the petition under Section 482 of the Code of Criminal Procedure, 1973 was maintainable when an alternate statutory remedy of revision under Section 397 of the Code of Criminal Procedure, 1973 was available, and whether the case disclosed exceptional circumstances warranting exercise of inherent jurisdiction.

Analysis: The available remedy of revision under the Code was treated as the appropriate course where the impugned order was revisable. The inherent power under Section 482 is residuary and extraordinary, to be exercised sparingly and with caution only in rare cases where interference is necessary to prevent abuse of process or secure the ends of justice. On the facts pleaded, no specific averment or material was shown to establish any extraordinary circumstance justifying bypass of the revisional remedy. A mere assertion of territorial jurisdiction or reliance on the impugned order did not supply a basis to invoke inherent jurisdiction in place of the statutory revisional remedy.

Conclusion: The petition under Section 482 of the Code of Criminal Procedure, 1973 was held not maintainable and the petitioners were relegated to the revisional remedy.

Final Conclusion: The challenge to the impugned order failed at the threshold for want of maintainability under the inherent jurisdiction of the High Court.

Ratio Decidendi: Where a specific and efficacious statutory revisional remedy exists, inherent jurisdiction under Section 482 of the Code of Criminal Procedure, 1973 is not to be invoked unless extraordinary circumstances are shown to prevent abuse of process or secure the ends of justice.

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