At the discharge stage, courts assess only whether a prima facie case exists and must not conduct a mini-trial.

The revisionists challenged the order dated 15 September 2025 rejecting their discharge application in a Sessions Trial arising from Case Crime No. 138 of 2023, registered under Sections 376 and 506 IPC.

They also challenged the charge-sheet dated 11 June 2023 and cognizance order dated 26 June 2023.

The revisionists relied on alleged inconsistencies in the victim’s account of the incident’s date and time, the absence of an independent witness, the delay in lodging the FIR, and a doctor’s statement concerning the alleged injection.

The State opposed the revision, submitting that the discharge order was reasoned and lawful.

The Court noted that the trial court had considered the grounds raised, including the victim’s explanation for the delay and the accused’s admission that he worked at the hospital where the incident allegedly occurred.

1. Whether the material collected by the prosecution disclosed a prima facie case sufficient to refuse discharge, notwithstanding the revisionists’ challenges to the victim’s account and the alleged evidentiary inconsistencies.

2. Whether the impugned discharge and cognizance orders disclosed an error, perversity, or other ground warranting interference in criminal revision.

At the discharge or charge-framing stage under Sections 227 and 228 CrPC, the court considers whether the prosecution material, taken at face value, gives grounds to presume that the accused committed the offence; it does not conduct a mini-trial or determine the material’s truthfulness, sufficiency for conviction, or ultimate acceptability.

The court may sift the material only to assess whether a prima facie case exists.

The Court relied on Manjit Singh Virdi v. Hussain Mohammed Shattaf, (2023) 7 SCC 633; State of Rajasthan v. Ashok Kumar Kashyap, (2021) 11 SCC 191; P. Vijayan v. State of Kerala, (2010) 2 SCC 398; and other authorities on discharge and charge.

Revisional jurisdiction is limited and is generally directed to correcting patent defects, jurisdictional or legal errors, or findings based on no evidence, ignored material evidence, or arbitrary or perverse exercise of discretion; it is not to be exercised routinely.

The Court also observed that delay in reporting sexual offences and the absence of independent witnesses do not, by themselves, establish that the prosecution case is false.

Applying the limited discharge-stage inquiry, the Court found that the victim’s statements and the other prosecution material were sufficient for the matter to proceed to trial.

It held that the trial court had addressed the grounds raised in the discharge application, including the delay in lodging the FIR, which had been explained by the victim and a witness, and the accused’s presence at the hospital.

The alleged contradictions and the doctor’s statement did not justify weighing the evidence or assessing its ultimate reliability at this stage.

The Court found no illegality, irregularity, or perversity in the impugned orders warranting revisional intervention.

It refused the relief sought and dismissed the criminal revision.