Supervisory jurisdiction cannot re-weigh evidence, and a company's later name change does not invalidate a valid cheque dishonour complaint.

Supervisory jurisdiction under Article 227 and inherent power under Section 482 CrPC cannot be used to re-appreciate evidence or act as an appellate forum; interference is confined to patent legal error, perversity, absence of evidence, or miscarriage of justice, and the concurrent conviction under Section 138 NI Act was upheld because the cheque, dishonour, statutory notice, and non-payment were proved. A later change in the complainant company's name or status does not by itself invalidate a complaint validly instituted by an authorised representative, and omission to amend the cause title did not affect the maintainability or validity of the proceeding.

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Issues: (i) Whether the High Court, in exercise of jurisdiction under Article 227 of the Constitution of India and Section 482 of the Code of Criminal Procedure, 1973, could re-assess the evidence and interfere with the concurrent conviction under Section 138 of the Negotiable Instruments Act, 1881; (ii) Whether failure to amend the cause title or complaint to reflect the company's subsequent change of name/status rendered the conviction and the criminal proceeding invalid.

Issue (i): Whether the High Court could re-assess the evidence and interfere with the concurrent conviction under Section 138 of the Negotiable Instruments Act, 1881.

Analysis: The supervisory power under Article 227 and the inherent power under Section 482 of the Code of Criminal Procedure, 1973 are extraordinary and discretionary. They are not appellate powers and do not permit the High Court to re-appreciate evidence or substitute its own findings for those recorded by the subordinate courts. Interference is warranted only where there is patent legal error, perversity, absence of evidence, or miscarriage of justice. The record showed proof of cheque issuance, dishonour for insufficiency of funds, statutory notice, and non-payment within the prescribed period, satisfying the ingredients of Section 138 of the Negotiable Instruments Act, 1881.

Conclusion: The High Court could not re-assess the evidence or disturb the concurrent findings, and the conviction under Section 138 was upheld.

Issue (ii): Whether failure to amend the cause title or complaint to reflect the company's subsequent change of name/status rendered the conviction and the criminal proceeding invalid.

Analysis: The complaint was instituted by a duly authorised representative, and subsequent authorisation was also placed on record. A change in the company's name or status does not, by itself, nullify proceedings already commenced in the earlier name. The legal position recognised under Section 23(1) of the Companies Act, 1956 permits continuation of proceedings in the company's old name after change of name, and the proceeding was not shown to be invalid on that ground.

Conclusion: The omission to amend the cause title did not affect the maintainability or validity of the proceeding or the conviction.

Final Conclusion: The revisional challenge failed on both the supervisory-jurisdiction point and the company-name objection, and the concurrent conviction and sentence were left undisturbed.

Ratio Decidendi: Supervisory and inherent jurisdiction cannot be used as a substitute for appeal to re-weigh evidence, and a criminal complaint is not invalidated merely because the complainant company later changes its name if the proceeding was validly instituted and otherwise satisfies the statutory requirements.

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