Revisional Court cannot re-appreciate evidence unless the trial court's dismissal of a complaint is patently illegal or perverse.

The applicant, a practicing advocate, filed a complaint against several individuals, including police personnel, alleging various offenses under the IPC, the SC/ST (Prevention of Atrocities) Act, 1989, and the Gujarat Money Lenders Act.

The applicant claimed that during the execution of a warrant against another individual, the police committed grave offenses against him.

The Trial Court called for a police report under Section 210 of the CrPC and, after considering the report and electronic evidence (a video in a pen drive), dismissed the complaint under Section 203 of the CrPC on January 24, 2025.

The applicant challenged this dismissal via the present revision application, alleging the order was based on conjectures.

1. Whether the Trial Court committed a jurisdictional or legal error in dismissing the criminal inquiry under Section 203 of the CrPC based on the available evidence.

2. Whether the High Court, in its revisional jurisdiction under Section 397 of the CrPC, should interfere with the discretionary findings of the subordinate court.

The Court applied Section 203 of the Code of Criminal Procedure regarding the dismissal of a complaint where no sufficient ground for proceeding exists.

It heavily relied on the scope of revisional jurisdiction defined under Section 397 of the CrPC, guided by the precedent K. Ravi Vs. State of Tamil Nadu & Anr. (AIR 2024 SC 4074), which establishes that revision is supervisory, not appellate, and should only be exercised in cases of patent illegality, manifest perversity, or jurisdictional error.

The Court examined the Trial Court’s reasoning, noting that the subordinate judge had meticulously perused the Investigating Officer's report and electronic evidence.

The analysis highlighted that video recordings of the incident contradicted the applicant's claims of being beaten or dragged, and medical certificates failed to link the applicant’s physical complaints to any police action.

The High Court reasoned that since the Trial Court had assigned cogent, detailed reasons for finding no prima facie case, the High Court could not re-appreciate the evidence or substitute its own view for that of the Trial Court.

The applicant failed to demonstrate any "patent illegality" or "material irregularity" that would meet the high threshold for revisional interference.

It concluded that there was no jurisdictional error or perversity in the dismissal of the complaint.

Consequently, the Criminal Revision Application was dismissed, and the rule was discharged.