Inherent jurisdiction under Section 482 CrPC cannot replace an available appeal or revision absent abuse of process or jurisdictional error.

Inherent jurisdiction under Section 482 CrPC cannot be used to bypass an available statutory appeal or revision remedy unless interference is needed to prevent abuse of process or secure the ends of justice. The High Court found no jurisdictional error or abuse in the trial court's directions releasing only personal belongings and articles not forming part of the case property, and it noted that the recall application was dismissed because the original order had been passed in counsel's presence. The challenge therefore failed and the Section 482 petition was held not maintainable.

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Issues: Whether a petition under Section 482 of the Code of Criminal Procedure, 1973 was maintainable to challenge the orders of the trial court when an appeal or revision remedy was available, and whether the orders directing release of personal wearing apparel and dismissing the recall application suffered from any legal infirmity.

Analysis: The petition was founded on the grievance that the trial court had wrongly directed release of articles claimed to have been used for concealment of currency and had refused recall of the earlier order. The Court found that the record supported the trial court's view that only personal belongings and articles not forming part of the case property were ordered to be released, and that the recall application had been dismissed because the original order had been passed in the presence of counsel. The Court further held that where a specific statutory remedy by way of appeal or revision is available, inherent jurisdiction under Section 482 is not to be invoked as a substitute, particularly when no abuse of process or jurisdictional error is shown.

Conclusion: The petition under Section 482 was not maintainable and the challenge to the trial court's orders failed.

Ratio Decidendi: The inherent powers of the High Court cannot be used to bypass an available statutory appellate or revisional remedy, unless interference is necessary to prevent abuse of process or to secure the ends of justice.

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