Inherent criminal jurisdiction remains limited where complaint material shows no prima facie offence and the dispute is civil.

Interference under Section 482 of the Code of Criminal Procedure is limited where concurrent orders dismiss a private complaint show no patent illegality, perversity, jurisdictional error or material irregularity. At the stage of examining a complaint, the material must disclose sufficient grounds to proceed; dismissal is justified where it does not prima facie establish the alleged offences. The notes state that an unexplained delay of about five years, along with inadequate material on alleged forgery, shipment valuation and additional commission, failed to disclose a criminal offence. The dispute was characterised as essentially civil, supporting dismissal of the complaint.

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Issues: Whether interference under Section 482 of the Code of Criminal Procedure, 1973 was warranted with the concurrent orders dismissing the private complaint for want of sufficient grounds to proceed.

Analysis: Revisional scrutiny is confined to correctness, legality and propriety of the challenged order, and does not permit substitution of a possible alternate view absent patent illegality, perversity, jurisdictional error or material irregularity. At the stage of Sections 200 and 203 of the Code of Criminal Procedure, 1973, the material need only disclose sufficient grounds for proceeding; where it does not prima facie disclose the alleged offences, dismissal of the complaint is justified. The complaint was instituted about five years after the transaction without satisfactory explanation, and the material concerning the alleged forged communication, shipment valuation and additional commission did not establish a prima facie criminal offence. The dispute was essentially civil in nature.

Conclusion: No ground for interference with the orders dismissing the complaint was made out; the issue was decided against the petitioner.

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