Inherent powers cannot be used to circumvent the statutory bar against filing a second revision.

The petitioner, a retired Sub-Divisional Officer, alleged that after his retirement on 31.10.2017, the proposed accused persons forged documents to reduce his second higher pay scale from Rs.10,100/- to Rs.9,800/- to cause him financial loss.

The petitioner filed a private complaint alleging offences under Sections 418, 420, 467, 468, 471, and 34 of the IPC.

After recording statements under Sections 200 and 202 Cr.P.C., the Judicial Magistrate First Class (JMFC), Gwalior, dismissed the complaint on 11.09.2025 under Section 203 Cr.P.C., categorizing the dispute as a civil/service matter.

The Third Additional Sessions Judge, Gwalior, subsequently dismissed the criminal revision on 17.01.2026.

The petitioner then moved the High Court under Section 528 of the BNSS (Section 482 Cr.P.C.).

1. Whether the dispute regarding pay scale reduction and document preparation constitutes a criminal offence or is purely civil/service-related in nature.

2. Whether an inherent power petition under Section 528 BNSS / Section 482 Cr.P.C. is maintainable against concurrent findings when it effectively seeks a second revision.

The court primarily applied Section 203 of the Cr.P.C. regarding the dismissal of a complaint if no sufficient ground for proceeding exists.

It further relied on the legal principle that the inherent powers of the High Court under Section 528 BNSS (corresponding to Section 482 Cr.P.C.) cannot be exercised to circumvent the statutory bar against a second revision, as provided under the procedural code.

The court also emphasized the doctrine that concurrent findings of fact by subordinate courts should not be disturbed unless there is a patent illegality, jurisdictional error, or perversity.

The court reasoned that both the Trial Court and the Revisional Court had concurrently arrived at the finding that the dispute was essentially a service matter concerning pay fixation.

The court noted that the petitioner failed to demonstrate any "patent illegality" or "glaring miscarriage of justice" that would necessitate the invocation of inherent powers.

The court observed that the petitioner sought to re-agitate the same grounds previously rejected by the Revisional Court; however, such a petition is not maintainable as it would permit a "second revision" in disguise, which is statutorily barred.

Since the dispute pertained to administrative or civil remedies rather than criminal culpability, the dismissal of the complaint was deemed appropriate.

The High Court affirmed the concurrent findings of the lower courts and dismissed the petition, holding it to be devoid of merit.

No relief was granted to the petitioner.