Inherent criminal jurisdiction cannot replace revision, especially for belated omnibus challenges to distinct procedural orders.

Inherent jurisdiction under Section 528 BNSS, corresponding to Section 482 CrPC, is exceptional and must be used sparingly to prevent abuse of process or secure the ends of justice. A separate revisional remedy under Section 438 BNSS, corresponding to Section 397 CrPC, remains available to challenge the legality or correctness of orders such as rejection of discharge and framing of charges. A composite petition cannot bundle distinct orders passed at different stages of a criminal proceeding into one omnibus challenge, especially where the proceeding has substantially advanced and the petition is filed belatedly. The petition was therefore held not maintainable, and conversion into a criminal revision was declined.

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Issues: Whether a composite petition under the inherent jurisdiction could validly challenge multiple distinct orders passed at different stages of the criminal proceeding, and whether such jurisdiction could be invoked at a belated stage when revisional remedies were available and the trial had substantially progressed.

Analysis: The inherent power preserved under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, corresponding to Section 482 of the Code of Criminal Procedure, is available to prevent abuse of process or secure the ends of justice, but it is exceptional and must be exercised sparingly. The revisional jurisdiction under Section 438 of the Bharatiya Nagarik Suraksha Sanhita, 2023, corresponding to Section 397 of the Code of Criminal Procedure, is a specific remedy for correcting the legality, propriety, or correctness of orders, and the petitioning party had an efficacious remedy against the orders rejecting discharge and framing charges. The petition sought to assail the entire criminal proceeding along with separate judicial orders rendered at different stages, but those orders arose from distinct judicial exercises and could not be rolled into one omnibus challenge. The petition was also filed after substantial delay, after the trial had progressed and witnesses had been examined, which showed an attempt to bypass the statutory remedy and use inherent jurisdiction as a substitute for revision.

Conclusion: The petition was held to be not maintainable, and no leave was granted to convert it into a criminal revision.

Final Conclusion: The challenge to the criminal proceeding and the connected orders was rejected at the threshold on maintainability, leaving the petitioner to pursue the trial process and not the extraordinary inherent jurisdiction.

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