Revisional jurisdiction does not permit reappraisal of concurrent findings absent manifest illegality or perversity.

The revisionist challenged four appellate judgments affirming his convictions in separate criminal cases arising from alleged land-sale fraud.

The complainants alleged that the revisionist entered into agreements or Memoranda of Understanding for the sale of different parcels of land at Kotdwar, received sale consideration through cash, cheques and RTGS/banking transactions, but was not the recorded tenure-holder, failed to execute the sale deeds, and did not refund the amounts received.

The Additional Chief Judicial Magistrate convicted the revisionist for offences under Sections 420 and 406 IPC; Section 420 IPC; Sections 420 and 423 IPC; and Sections 420 and 406 IPC, respectively.

The Additional Sessions Judge, Kotdwar, affirmed those convictions in the connected criminal appeals.

The revisionist contended that the transactions occurred in 2020–2021 whereas the FIRs were lodged in 2023, that dishonest intention was not established, and that the courts below had failed to appreciate material contradictions in the prosecution evidence.

Whether the concurrent findings convicting the revisionist for offences under Sections 406, 420 and 423 IPC suffered from manifest illegality, perversity, material irregularity or miscarriage of justice warranting interference in revisional jurisdiction?

Whether the prosecution evidence sufficiently established that the revisionist received substantial sale consideration, failed to execute the sale deeds despite lacking title, and failed to refund the amounts, thereby substantiating the alleged offences?

Whether the alleged delay in lodging the FIRs, contradictions in the prosecution evidence, and absence of proof of dishonest intention justified setting aside the convictions?

The Court applied Sections 406, 420 and 423 of the Indian Penal Code, under which the revisionist had been convicted in the respective cases.

It reiterated that the jurisdiction of a criminal revision court is limited and that concurrent factual findings are not ordinarily re-appreciated merely because another view is possible.

Interference is justified only where the findings disclose manifest illegality, perversity, gross miscarriage of justice, material irregularity or jurisdictional error.

The Court further applied the evidentiary principle that documentary records relating to agreements and payment transactions, corroborated by witness testimony, may establish receipt of consideration and the subsequent failure to perform the promised transaction or return the money.

The Court found that the revisionist’s execution of agreements or Memoranda of Understanding and receipt of substantial amounts from the complainants were not seriously disputed.

The record showed that payments were made through cash, cheques and RTGS or other banking channels, while the revisionist neither secured execution of the sale deeds nor refunded the money, despite not being the recorded tenure-holder of the land.

The Trial Court had considered the oral and documentary evidence, and the Appellate Court had independently reassessed the material before affirming the convictions.

The revisionist’s objections concerning delay, contradictions and dishonest intention essentially sought a fresh re-appreciation of evidence.

As no manifest illegality, perversity, material irregularity or jurisdictional error was demonstrated, the limited revisional jurisdiction could not be invoked.

It held that the concurrent convictions and sentences were supported by the evidence and disclosed no ground for revisional interference.

Accordingly, all four criminal revisions were dismissed, and no order as to costs was made.