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Supreme Court of India 2025-12-19 allowed

Syed Shahnawaz Ali vs State of Madhya Pradesh & Ors

Bench: 2 — Sanjay Karol, Manoj Misra

In Brief

The appellant's father filed a criminal revision petition challenging the discharge of certain charges against accused persons. Following the father's death, the High Court dismissed the revision as abated, finding no statutory provision allowing continuation. The Supreme Court held that criminal revisions do not automatically abate upon the revisionist's death, unlike appeals under Section 394 CrPC. As revisional jurisdiction is discretionary and focused on supervising criminal justice administration, revisions can continue after a revisionist's death, particularly when initiated by informants or complainants. The Court permitted the appellant, as a victim under Section 2(wa) CrPC, to assist in the resumed proceedings, emphasizing that victims may participate to further justice without formal substitution requirements.

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Criminal Procedure Revision Jurisdiction Abatement of Proceedings Victim Rights Access to Justice High Court Powers

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