Revisional court cannot reverse discharge order by substituting its view without finding patent illegality or perversity.

The petitioners’ seed godowns were seized on 25.10.2012 under the Essential Commodities Act, 1955. Following an auction order, the "Drumikaran" process was conducted on 08.01.2013

Subsequently, authorities alleged that the seals were tampered with and goods were missing, leading to an FIR under Sections 454, 457, 380, and 201 of the IPC

Upon investigation, the trial court discharged the petitioners on 18.03.2015, finding no prima facie case

The State challenged this via revision; the Revisional Court allowed the State's petition on 24.03.2018, set aside the discharge, and directed arrest warrants against the petitioners

1. Whether the Revisional Court exceeded its jurisdiction by substituting its own view for that of the Trial Court without finding patent illegality or perversity

2. Whether there existed sufficient material to meet the threshold of "grave suspicion" required to frame charges under Sections 454, 457, 380, and 201 IPC

The Court applied Sections 397 and 401 of the CrPC regarding revisional jurisdiction, noting it is supervisory, not appellate

It relied on the distinction between "mere suspicion" and "grave suspicion," where only the latter justifies a trial

The Court cited Union of India v. Prafulla Kumar Samal, establishing that a judge must sift evidence to find a prima facie case and not act as a mere "post office"

It further referred to Kanti Bhadra Shah v. State of West Bengal, noting that while detailed reasons aren't required for framing charges, the order must reflect a conscious application of mind

Finally, it integrated principles from Reema v. State of Rajasthan regarding the mandatory nature of procedural safeguards under the BNSS (analogous to CrPC)

The High Court found that the Revisional Court's order was "cursory, omnibus, and bereft of any demonstrable application of judicial mind"

The Court reasoned that the Revisional Court failed to identify any specific perversity or illegality in the Trial Court’s discharge order and instead simply substituted its own conclusion

Applying the doctrine of "grave suspicion," the Court observed that there was "not an iota of evidence" suggesting the petitioners committed trespass or theft

The Court emphasized that forcing individuals to face trial without a foundational factual nexus to the crime infringes upon the right to liberty

It concluded that the Revisional Court failed to conduct an independent analysis of the material to justify reversing a well-reasoned discharge

It held that the Revisional Court had transgressed its limits by reversing the discharge in the absence of patent illegality

The Trial Court’s order dated 18.03.2015, which discharged the petitioners of all charges, was affirmed

All pending stay petitions were disposed of