Delhi District Court
Richa Jain vs State on 2 May, 2026
IN THE COURT OF SH. ABHISHEK GOYAL,
ADDITIONAL SESSIONS JUDGE-03, CENTRAL
DISTRICT, TIS HAZARI COURTS, DELHI
CNR No.: DLCT01-001833-2026
CRIMINAL REVISION No.: 72/2026
1. SMT. RICHA JAIN,
R/o. H. No. A1/19,
Budh Vihar, Phase-I,
Delhi-110085.
2. SMT. NIDHI JAIN,
R/o. H. No. A1/19,
Budh Vihar, Phase-I,
Delhi-110085.
3. SMT. POOJA JAIN,
R/o. H. No. A1/19,
Budh Vihar, Phase-I,
Delhi-110085.
4. SMT. SAKSHI JAIN,
R/o. H. No. A1/19,
Budh Vihar, Phase-I,
Delhi-110085. ... REVISIONISTS/
PETITIONERS
VERSUS
1. STATE (NCT OF DELHI),
Through SHO,
PS. Jama Masjid, Delhi.
2. SHRI. SUDHIR JAIN,
S/o. Late Shri. Om Parkash Jain,
R/o. 1/4775, Street No. 8,
Balbir Nagar Extension,
Shahdara, Delhi-110032. ... RESPONDENTS
Date of e-filing : 29.01.2026
Date of institution : 30.01.2026
Date when judgment was reserved : 20.04.2026
Date when judgment is pronounced : 02.05.2026
JUDGMENT
1. The present revision petition has been filed under CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 1 of 27 Digitally signed by ABHISHEK ABHISHEK GOYAL GOYAL Date:
2026.05.02 16:02:41 +0530 Section 438 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (hereinafter referred to as 'BNSS')/pari materia with Section 397 of the Code of Criminal Procedure, 1973 (hereinafter, referred to as 'Cr.P.C./Code'), seeking setting aside of the order dated 29.11.2025 (hereinafter referred to as the 'impugned order'), passed by learned Judicial Magistrate First Class-13/Ld. JMFC-13, Central, Tis Hazari Courts, Delhi (hereinafter referred to as the 'Ld. JMFC/Ld. Trial Court'), in case bearing, 'Richa Jain v. Sudhir Jain, Ct. Case No. 2751/2023', PS. Jama Masjid.
Pertinently, by virtue of the impugned order the Ld. Trial Court dismissed the application, preferred by the revisionists namely, Richa Jain, Nidhi Jain, Pooja Jain, Sakshi Jain (hereinafter collectively referred to as the 'revisionists') in terms of the provisions under Section 156(3) Cr.P.C., though, listing the matter for Pre-Summoning Evidence/PSE.
2. Succinctly, the facts leading to the initiation of the present proceedings is the complaint under Section 200 Cr.P.C. along with an application under Section 156(3) Cr.P.C., filed by the revisionists before the Ld. Trial Court. Pertinently, in their complaint/application, the revisionists inter alia proclaimed that one, Smt. Chameli Devi Jain (since deceased) was an allottee of the property bearing no.; 1385/IV Gali Guliyan Dariba Kalan, Delhi (hereinafter referred to as the 'shop/premise') from J.J. Slum Vikas Kutir. Correspondingly, as per the revisionists, in the year, 1968, Shri. Tara Chand (since deceased) and Smt. Chameli Devi (since deceased) adopted one Shri. Niwas Jain from Shri. Om Parkash Jain (since deceased) and Smt. Kamla Jain (since deceased) by way of an adoption deed. Markedly, as per the revisionists, after Shri. Niwas Jain was adopted in the said family, CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 2 of 27 Digitally signed ABHISHEK by ABHISHEK GOYAL GOYAL Date: 2026.05.02 16:02:48 +0530 he commenced operation of his business from the shop/premise and subsequent to the demise of Shri. Niwas Jain, his legal heirs, i.e., the revisionists commenced operation of their business from the said premise. The revisionists further proclaimed under their complaint/application that due to some unavoidable circumstances, they/the revisionists could not operate their business operations for around 10-15 (ten-fifteen) days from the said premise. However, when the revisionists are asserted to have returned to the premise/shop on 28.08.2023, it was noted by the revisionists that respondent no. 2 had broken the locks of the said premise/shop.
2.1. Markedly, it is further chronicled under the revisionists' complaint/application that on further enquiry at the aforesaid point in time, it was determined that not only did respondent no. 2, trespassed in the said premise/shop, after breaking open the locks thereof, rather, respondent no. 2 also fixed/placed his name plate on the said premise. Congruently, as per the revisionists, when they again visited the premise, it was observed by them that the goods/belongings, furniture, weighing apparatus, etc., which were kept inside the premise, were missing. As per the revisionists, the said articles monetarily amounted/valued to a sum of Rs. 12,00,000/- (Rupees Twelve Lakhs only) and on enquiry, as per the revisionists, it was further determined by them that respondent no. 2 intended to sell/transfer the entire such property. In fact, it was specifically proclaimed by the revisionists under their complaint/application that respondent no. 2 had already wrongfully disposed of revisionists' goods, furniture, weighing apparatus and other assets, which were kept inside the premise/shop. It was further proclaimed by the CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 3 of 27 Digitally signed by ABHISHEK ABHISHEK GOYAL GOYAL Date:
2026.05.02 16:02:54 +0530 revisionists under the complaint/application that such alleged intrusion on the property, caused financial loss to the revisionists as well as subjected the revisionists and their family to significant emotional distress.
2.2. Congruently, as per the revisionists, respondent no. 2 filed a suit for partition/possession as well as permanent injunction before the concerned Ld. District Judge/Ld. Additional District Judge, Central District, Tis Hazari Courts, where he/respondent no. 2 is asserted to have admitted the fact of revisionists' possession of the premise/shop. Ergo, under aforenoted facts and circumstances, the revisionists are avowed to have approached the concerned police officials against the alleged acts of respondent no. 2's trespassing as well as illegally occupying the premise/shop. However, as per the revisionists, no FIR was registered on their complaint. Congruently, the revisionists are also asserted to have made a complaint in writing to the concerned SHO, PS Jamia Nagar; ACP, Darya Ganj, New Delhi; and DCP, Darya Ganj, New Delhi against respondent no. 2, however, no action was taken against respondent no. 2. It is further asserted on behalf of the revisionists that considering the utter inaction on the part of the concerned police officials, despite the demonstration of commission of several cognizable offences, the revisionists moved the Ld. Trial Court by means of the aforenoted complaint under Section 200 Cr.P.C. along with an application/entreaty for registration of FIR, in terms of the provisions under Section 156(3) Cr.P.C. Relevantly, the Ld. JMFC/Ld. Trial Court vide order dated 15.12.2023, directed the concerned police official/SHO to file of action taken report/ATR/status report on the complaint filed by/on behalf of the CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 4 of 27 Digitally signed by ABHISHEK ABHISHEK GOYAL GOYAL Date:
2026.05.02 16:03:05 +0530 revisionists inter alia under the following observations;
"***Heard. Perused.
Ld. Counsel for complainant submits that complainant had approached SHO concerned with the present complaint, but no action had been taken so far. Accordingly, SHO PS Jama Masjid is directed to file an action taken report stating the following:-
1. Whether any complaint has been made/received by the complainant in the police station.
2. If yes, whether any action has been taken on the complaint.
3. Whether as a result of investigation/inquiry, any cognizable offence has been made out against the accused person and whether any action has been taken by the police.
4. If yes, whether any FIR has been registered & status of investigation.
5. If no cognizable offence has been made out, whether the complainant has been informed accordingly.
Copy of the complaint alongwith the annexures be supplied to the concerned Naib Court, PS Jama Masjid today.
Put up for filing of report on***"
(Emphasis supplied) 2.3. Consequently, in compliance of the aforesaid directions of the Ld. Trial Court, Status Report came to be filed by/on behalf of the concerned SHO before the Ld. Trial Court on 15.02.2025, inter alia, noting, as under;
"*** It is submitted that complainant mentioned that she is the resident of H. No. A1/19, Budh Vihar, Phase-1, Delhi. She further mentioned that Smt. Chameli Devi Jain was the allottee from JJ Slum Vikas Kutir of property bearing No. 1385/IV, Gali Guliyan Dariba Kalan, Delhi and in the year 1968 as per the family settlement Lt. Tara Chand and Smt. Chameli Devi had adopted Sri Niwas Jain from Lt. Om Prakash Jain and Lt. Smt. Kamla Jain. After the demise of Sri Niwas (complainant's husband), legal heirs i.e complainant started business at 1385, Bazar Guliyan, Delhi. She alleged that in her absence for CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 5 of 27 Digitally signed by ABHISHEK ABHISHEK GOYAL GOYAL Date:
2026.05.02 16:03:16 +0530 10-15 days, when she visited that above said shop, the alleged person broke the locks of the property and started running business. She alleged that the alleged persons has illegally occupied the above said address/shop.
In this regard, it is submitted that an enquiry was got conducted into the matter. During the course of enquiry, the complainant was contacted who told that she is the actual owner of the said property i.e 1385/IV, Gali Guliyan Dariba Kalan, Delhi and was asked to provide the documents of the said property. Further, the alleged party i.e Sudhir Jain was enquired who told that he has purchased the said property from his brother and paid Rs. 4 Lacs for the said property. He further told that he is the owner, he was also directed to wide the related documents. Both parties have provided notary documents of the said property and not provide any registered documents.
Further, a letter was sent to Sub Registrar, Asaf Ali Road, Delhi on 02.07.2024 for verification of actual owner of property No. 1385, Bazaar Guliyan, Delhi. A letter/reply has been received from the office of Sub Registrar-III, 4/7 Asaf Ali Road, Delhi vide letter No. F.No. SR- III/MISC./2024/1569 dated 04.07.2024 mentioning that office maintain daily transaction wise record as per registration number, volume number, date and etc, no date is maintained by name and property address. Hence, it is not possible trace out the document without registration no. and volume number and date.
On Perusal of record it was found that, the complaint was filed by complainant in the year 2023 and the same was filed with remarks that matter is related to property dispute and no such incident of lock breaking has taken place.
Keeping in view of above facts and enquiry conducted so far, it is submitted that both parties are having the notary related documents and no one is having registered documents of the said property due to which it is difficult to find out the ownership of the said property from Sub-Registrar office. The undersigned is ready to abide by the direction passed by the Hon'ble Court.***"
(Emphasis supplied) 2.4. Subsequently, upon the arguments being addressed CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 6 of 27 Digitally signed by ABHISHEK ABHISHEK GOYAL GOYAL Date:
2026.05.02 16:03:21 +0530 by/on behalf of the revisionists as well as on consideration of the action taken report(s)/status report(s), the Ld. Trial Court dismissed the revisionists' application under Section 156(3) Cr.P.C. vide its order dated 29.11.2025/impugned order inter alia under the following observations;
"*** 05. Record perused. Submissions heard.
06. At the outset, it is imperative to keep in consideration the circumstances when an application u/s. 156 (3) Cr.PC should be entertained by the Court.
In Ms. Skipper Beverages P. Ltd. Vs. State 2002 Crl. L.J. NOC 333 (Delhi), the circumstances when the powers of magistrate U/s 156 (3) Cr.P.C should be exercised, has been explained. It was held that:*** *** *** ***
07. Moreover, it has been held in Gulab Chand Upadhyaya Vs State Of U.P. And Ors. 2002 CriLJ 2907 that "where the complainant is in possession of the complete details of all the accused as well as the witnesses who have to be examined and neither recovery is needed nor any such material evidence is required to be collected which can be done only by the police, no "investigation" would normally be required and the procedure of complaint case should be adopted."
08. The word used in Section 156(3) Cr.PC/Section 175 BNSS is 'may'. The powers under this section are discretionary in nature and an FIR cannot be registered mechanically by invoking these provisions.
09. In view of the material on record, preliminary enquiry report of the IO and after hearing the submissions of counsel, it is clear that the identity of the accused is known to the complainant, all the facts and circumstances of the case appears to be within the knowledge of the complainant and evidence can be conveniently taken without assistance of police investigation. In the facts of the present case, there appears no requirement of police investigation. Further, if there is any need, police inquiry can be ordered u/s 202 Cr.P.C. for verification of any documents or for any other purpose, if required.
10. Accordingly, with the above observations, application u/s 156(3) Cr. PC is dismissed.
CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 7 of 27
Digitally signed
ABHISHEK by ABHISHEK
GOYAL
GOYAL Date: 2026.05.02
16:03:26 +0530
11. However, I take cognizance under section 200 Cr.PC. The case be re-listed for pre-
summoning evidence. The complainant is at liberty to prove his case by way of evidence and the complainant is directed to produce evidence and witnesses at his own efforts.
12. Put up for PSE on ***"
(Emphasis supplied)
3. Ld. Counsel for the revisionists submitted that the impugned order was passed by the Ld. Trial Court on mere conjunctures, surmises and in contravention of the settled cannons of law, deserving the same to be set aside at the outset, as suffering with gross illegality. In this regard, Ld. Counsel further submitted that the impugned order was passed by the Ld. Trial Court on mere assumptions and that no sound and/or cogent reasons have been delineated under the said order. Ld. Counsel further submitted that while passing the impugned order, the Ld. Trial Court further failed to appreciate the full facts and passed the impugned order, whimsically, ignoring the material facts. As per the Ld. Counsel, Ld. Trial Court erred in dismissing the revisionists' application under Section 156(3) Cr.P.C., without passing a speaking order and without considering the prima facie offences, committed by respondent no. 2 in the instant case. In this regard, Ld. Counsel for the revisionists further vehemently contended that while passing the impugned order, the Ld. Trial Court failed to appreciate that the allegations under the revisionists' complaint/application disclose serious cognizable offences of theft, criminal trespass, forgery, and conspiracy, which cannot be relegated to the realm of a civil dispute. Congruently, it was submitted that the acts complained of, involve forcible entry in the premise; removal of valuable articles worth approximately Rs.12,00,000/- (Rupees Twelve Lakhs only); as well as deliberate CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 8 of 27 Digitally signed by ABHISHEK ABHISHEK GOYAL GOYAL Date:
2026.05.02 16:03:32 +0530 interference in revisionists' lawful possession of the premise, by removal of the revisionists' name plate, bringing the same within the ambit of criminal offences under Indian Penal Code, 1860/IPC, necessitating immediate police intervention/investigation under Section 156(3) Cr.P.C.
3.1. Ld. Counsel for the revisionists further submitted that the Ld. Trial Court further erred in not considering that the police officials, instead of investigating the allegations of forcible entry, theft, and forgery in relation to the premise/shop, merely dismissed the entire issue, erroneously terming it as a 'mere civil dispute'. As per the Ld. Counsel, such abdication of statutory duty under Sections 154/156 Cr.P.C., deprived the revisionists of their rightful claim as well as their entitlement to seek fair investigation.
Even otherwise, as per the Ld. Counsel, Ld. Trial Court's reliance on an incomplete and unilateral Status Report/ATR amounted to non-application of mind. It was further submitted by the Ld. Counsel that the Ld. Trial Court failed to appreciate that respondent no. 2, with a malafide intention, firstly withdrew his civil suit and, thereafter, while acting in connivance/conspiracy with his other associates, illegally occupied the premise, after committing theft of valuable property. Ergo, it was argued that the said sequence of events, quite lucidly demonstrate deliberate misuse of judicial process and a criminal design by respondent no. 2, to deprive the revisionists of their lawful claim to the premise/shop/property in question. Correspondingly, it was argued that the Ld. Trial Court failed to appreciate that respondent no. 2, further removed revisionists' name plate from the premise, with a sole intention to obliterate their lawful possession and identity, and to project false ownership. As per the Ld. Counsel, CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 9 of 27 Digitally signed by ABHISHEK ABHISHEK GOYAL GOYAL Date:
2026.05.02 16:03:38 +0530 such removal, clearly indicated dishonest intention and conspiracy, showing that respondent no. 2 intended to invade on revisionists' rights as well as to mislead authorities. 3.2. Ld. Counsel for the revisionists further submitted that the Ld. Trial Court further failed to appreciate the sequence of withdrawal of the civil suit, forcible entry, theft of property, removal of name plate, and continued illegal occupation, on the part of respondent no. 2, clearly demonstrates criminal design on the part of the said respondent/accused, necessitating police investigation. Further, as per the Ld. Counsel, while passing the impugned order, Ld. Trial Court failed to appreciate that the revisionists were victims in the hands of respondent no. 2 and other police officials, where not only was their premise/shop illegally trespassed, rather, the revisionists were also subjected to mental harassment. However, despite the same, as per the Ld. Counsel, no FIR has been registered till date. Ld. Counsel further submitted that the Ld. Trial Court also failed to recognize the basic principle and purpose of registration/lodging of FIR. In this regard, Ld. Counsel fervently argued that it is settled law that when an offence/crime is opined/determined to be cognizable in nature, FIR ought to be registered. As per the Ld. Counsel, registration of FIR is the incipient stage of invocation of criminal machinery, setting the criminal justice system in motion and enabling the police to look in the situation. However, it was argued that the Ld. Trial Court wrongly dismissed the revisionists' application under Section 156(3) Cr.P.C. vide the impugned order on patently erroneous observations. In this regard, it was reiterated that it is a legal requirement to register/lodge FIR when a person provides information about the commission of cognizable offence. Ld. CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 10 of 27 Digitally signed by ABHISHEK ABHISHEK GOYAL GOYAL Date:
2026.05.02 16:03:51 +0530 Counsel further vehemently asserted that only the police machinery is equipped to conduct a thorough inquiry/investigation in the instant case. Further, as per the Ld. Counsel, the revisionist in his individual capacity, does not have the means to investigate, dig out, search and seize the material and evidence in the instance case, necessary to unearth the real truth in the instant case. Ld. Counsel further reiterated in this regard that it is only the fair police officials/authorities, who can unearth the truth as well as collect the evidence of such a nature, which fact was not considered by the Ld. Trial Court, while passing the impugned order.
3.3. Ld. Counsel for the revisionists further submitted that Ld. Trial Court erred in not properly appreciating the necessity of uncovering numerous critical factors during the investigation. Ld. Counsel further strenuously reiterated that the Ld. Trial Court failed to recognize the inevitability of custodial interrogation of respondent no. 2, which is crucial for the recovery of the evidence and statement. Correspondingly, as per the Ld. Counsel, the ATRs, filed by the police officials before the Ld. Trial Court were completely silent with respect to the investigation conducted on the revisionists' complaint. In this regard, it was further submitted that a scrupulous analysis of the Status Report/ATR would demonstrate that the concerned police officials did not even make endeavor to ascertain the true and correct facts of the case. It was further submitted that the Ld. Trial Court fell in grave error in not appreciating the basic tenets of law that a person is constrained to approach the Magistrate/Ld. Trial Court through an application under Section 156(3) Cr.P.C only on the failure/refusal of the police official to entertain a CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 11 of 27 Digitally signed by ABHISHEK ABHISHEK GOYAL GOYAL Date:
2026.05.02 16:03:57 +0530 criminal complaint. Ergo, Ld. Counsel reiterated with vehemence that the impugned order was passed by the Ld. Trial Court in violation of facts as well as law. Consequently, Ld. Counsel for the revisionists entreated that the impugned order, being passed in gross violation of law and settled judicial precedents, deserves to be set aside, outrightly and directions be issued for registration of FIR as well as consequent, investigation. In support of the said contentions, reliance was placed upon the decisions in; Anurag Bhatnagar v. State (NCT of Delhi), 2025 SCC Online SC 1514; Om Prakash Ambadkar v. State of Maharashtra, (2026) 2 SCC 622; and Kanishk Sinha v. State of W.B., 2024 SCC OnLine SC 4823.
4. Per contra, Ld. Addl. PP for the State/respondent no. 1 submitted that the impugned order was passed by the Ld. Trial Court after due appreciation of the facts and circumstances of the present case and, as such, deserves no interference by this Court. It was further submitted that no irregularity, impropriety, or incorrectness can be attributed to the impugned order, which was passed by the Ld. Trial Court, cognizant of the principles of law, as well as wary of the facts and circumstances brought forth.
Accordingly, Ld. Addl. PP for the State entreated that the instant petition be dismissed as amounting to gross abuse of process of law.
5. The arguments of Ld. Counsel for the revisionists and that of Ld. Addl. PP for the State/respondent no. 1 have been heard as well as the records, including the Ld. Trial Court records as well as the case laws, relied upon by the revisionists have been thoroughly perused.
6. Before proceeding with the determination of the CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 12 of 27 Digitally signed by ABHISHEK ABHISHEK GOYAL GOYAL Date:
2026.05.02 16:04:01 +0530 merits of the present case, this Court deems it apposite to outrightly make a reference to the relevant provisions under law/Section 438 BNSS1, as under;
"438. Calling for records to exercise powers of revision-(1) The High Court or any Sessions Judge may call for and examine the record of any proceeding before any inferior Criminal Court situate within its or his local jurisdiction for the purpose of satisfying itself or himself as to the correctness, legality or propriety of any finding, sentence or order, recorded or passed, and as to the regularity of any proceedings of such inferior Court, and may, when calling, for such record, direct that the execution of any sentence or order be suspended, and if the accused is in confinement that he be released on his own bond or bail bond pending the examination of the record.
*** *** *** (2) The powers of revision conferred by sub-
section (1) shall not be exercised in relation to any interlocutory order passed in any appeal, inquiry, trial or other proceeding...."
(Emphasis supplied)
7. Pertinently, from a perusal of the aforesaid, it is quite evident that the revisional jurisdiction of this Court can be agitated either suo motu or an application of parties, that too in a case(s) where there is a palpable error, non-compliance of the provision of law, decision of Trial Court being completely erroneous or where the judicial decision is exercised arbitrarily. In this regard, reliance is placed upon the decision of the Hon'ble Supreme Court in Amit Kumar v. Ramesh Chander, (2012) 9 SCC 460, wherein the Hon'ble Court while explicating the various contours of the provision under Section 397 Cr.P.C. (pari 1 Pari materia provision under Section 397 Cr.P.C., which provides, "397. Calling for records to exercise of powers of revision-(1) The High Court or any Sessions Judge may call for and examine the record of any proceeding before any inferior Criminal Court situate within its or his local jurisdiction for the purpose of satisfying itself or himself as to the correctness, legality or propriety of any finding, sentence or order, recorded or passed, and as to the regularity of any proceedings of such inferior Court, and may, when calling for such record, direct that the execution of any sentence or order be suspended, and if the accused is in confinement, that he be released on bail or on his own bond pending the examination of the record.***Explanation - All Magistrates, whether Executive or Judicial, and whether exercising original or appellate jurisdiction, shall be deemed to be inferior to the Sessions Judge for the purposes of this sub-section and of Section 398.***(2) The powers of revision conferred by sub-section (1) shall not be exercised in relation to any interlocutory order passed in any appeal, inquiry, trial or other proceeding..." (Emphasis supplied) CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 13 of 27 Digitally signed by ABHISHEK ABHISHEK GOYAL GOYAL Date:
2026.05.02 16:04:06 +0530 materia with Section 438 of BNSS), observed as under:
"12. Section 397 of the Code vests the court with the power to call for and examine the records of an inferior court for the purposes of satisfying itself as to the legality and regularity of any proceedings or order made in a case. The object of this provision is to set right a patent defect or an error of jurisdiction or law. There has to be a well-founded error and it may not be appropriate for the court to scrutinise the orders, which upon the face of it bears a token of careful consideration and appear to be in accordance with law. If one looks into the various judgments of this Court, it emerges that the revisional jurisdiction can be invoked where the decisions under challenge are grossly erroneous, there is no compliance with the provisions of law, the finding recorded is based on no evidence, material evidence is ignored or judicial discretion is exercised arbitrarily or perversely. These are not exhaustive classes, but are merely indicative. Each case would have to be determined on its own merits..."
(Emphasis supplied)
8. Comparably, the Hon'ble High Court of Delhi in V.K. Verma v. CBI, 2022 SCC Online Del 1192, in a similar context noted as under;
"67. The revisional jurisdiction is not meant to test the waters of what might happen in the trial. The Revisional Court has to consider the correctness, legality or propriety of any finding inter se an order and as to the regularity of the proceedings of the court below. While doing so, the Revisional Court does not dwell at length upon the facts and evidence of the case, rather it considers the material only to satisfy itself about the legality and propriety of the findings, sentence and order and refrains from substituting its own conclusion on an elaborate consideration of evidence. In the instant case, the Petitioner has failed to make out a case for exercise of the revisional jurisdiction since there is no patent error in the impugned order on the face of record."
(Emphasis supplied)
9. Quite evidently, it may be noted from above that the revisional jurisdiction of the higher court is quite limited and CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 14 of 27 Digitally signed by ABHISHEK ABHISHEK GOYAL GOYAL Date:
2026.05.02 16:04:11 +0530 cannot be exercised in a routine manner. In fact, as aforenoted, the revisional Court can interfere only in the instances where an order of trial court was passed, unjustly and unfairly. Further, it is a settled law2 that trite law that in a case where the order of subordinate Court does not suffer from any illegality, "merely because of equitable considerations, the revisional Court has no jurisdiction to re-consider the matter and pass a different order in a routine manner." Reference in this regard is made to the decision in Taron Mohan v. State, 2021 SCC Online Del 312, wherein the Hon'ble High Court of Delhi expounded as under;
"9. The scope of interference in a revision petition is extremely narrow. It is well settled that Section 397 CrPC gives the High Courts or the Sessions Courts jurisdiction to consider the correctness, legality or propriety of any finding inter se an order and as to the regularity of the proceedings of any inferior court. It is also well settled that while considering the legality, propriety or correctness of a finding or a conclusion, normally the revising court does not dwell at length upon the facts and evidence of the case. A court in revision considers the material only to satisfy itself about the legality and propriety of the findings, sentence and order and refrains from substituting its own conclusion on an elaborate consideration of evidence."
(Emphasis supplied)
10. Notably in the context of the foregoing, it is further apposite to observe the settled law3 that in the case where the criminal complaint, filed before the Magistrate, discloses commission of a cognizable offence upon scrutiny, two courses are open to the Magistrate. Under such circumstance, such magistrate may opt to take cognizance under Section 190 Cr.P.C. and proceed to inquire into it in accordance with the procedure 2 Juned v. State of M.P., 2023 SCC OnLine MP 4458; and Dilip Damor v. State of M.P., 2024 SCC OnLine MP 958.
3Satyamuni Verma v. State (Govt. NCT of Delhi) & Ors., MANU/DE/0704/2014.
CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 15 of 27 Digitally signed by ABHISHEK ABHISHEK GOYAL GOYAL Date: 2026.05.02 16:04:16 +0530
laid down in Sections 200/202 Cr.P.C. In the alternate, such magistrate may refer the complaint to police under Section 156(3) Cr.P.C. for investigation, wherein magistrate would stay his hand till report under Section 173 Cr.P.C. is submitted by the police, on which further process of law would follow. Reference in this regard, is made to the decision of the Hon'ble High Court of Delhi in Qamar Jahan v. State (Govt. of NCT of Delhi), 2014 SCC Online Del 3745, wherein the Hon'ble Court remarked in the context of the foregoing as under;
"8. It is a well settled law that when criminal complaint is filed before the Magistrate and upon perusal it is found that it discloses a cognizable offence having been committed, two courses are open to the Magistrate. He may chose to inquire into the complaint by taking cognizance in exercise of his powers under Section 190 Cr.P.C. and proceed to inquire into it in accordance with the procedure laid down in sections 200 and 202 Cr.P.C. In the alternative, he may refer the complaint to police under Section 156(3) Cr.P.C. for investigation. In the latter case, the Magistrate, having given such direction would stay his hand till report under Section 173 Cr.P.C. is submitted by the police, on which further process of law would follow.
9. The Magistrate is not supposed to act mechanically and direct registration of FIR in each and every case in routine and casual manner. Criminal law is not expected to be set in motion on mere asking of a party. There has to be some substance in the complaint filed and it is only if it appears that the allegations are serious enough and establish the commission of cognizable offence required thorough investigation by the police, an FIR should be ordered to be registered.
10. In case Gulab Chand Upadhyay v. State of U.P., (2002) Crl.L.J. 2907, it was held that the use of the word "may" in Section 156(3) Cr.P.C. in contra distinction to the word "shall" in Section 154 Cr.P.C. clearly indicates that the Magistrate has the discretion to refuse registration of FIR..."
(Emphasis supplied)
11. Correspondingly, earlier the Hon'ble High Court of CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 16 of 27 Digitally signed ABHISHEK by ABHISHEK GOYAL GOYAL Date: 2026.05.02 16:04:22 +0530 Delhi in Skipper Beverages Pvt. Ltd. v. State, 2001 SCC Online Del 448, explicated the law in respect of the provisions under Section 156(3) Cr.P.C. in the following terms;
"7. It is true that Section 156(3) of the Code empowers a Magistrate to direct the police to register a case and initiate investigations but this power has to be exercised judiciously on proper grounds and not in a mechanical manner. In those cases where the allegations are not very serious and the complainant himself is in possession of evidence to prove his allegations there should be no need to pass orders under Section 156(3) of the Code. The discretion ought to be exercised after proper application of mind and only in those cases where the Magistrate is of the view that the nature of the allegations is such that the complainant himself may not be in a position to collect and produce evidence before the Court and interests of justice demand that the police should step in to held the complainant. The police assistance can be taken by a Magistrate even Under Section 202(1) of the Code after taking cognizance and proceeding with the complaint under Chapter XV of the Code as held by Apex Court in 20001 (1) Supreme Page 129 titled "Suresh Chand Jain Vs. State of Madhya Pradesh & Ors."..."
(Emphasis supplied)
12. Here, this Court deems it apposite to further refer to the decision of the Hon'ble High Court of Delhi in Anjuri Kumari v. State (NCT of Delhi), 2023 SCC Online Del 7570, wherein the Hon'ble Court reiterated that the directions for investigation under section 156(3) Cr.P.C. cannot be given by the Magistrate mechanically, rather, only on application of mind. Correspondingly, the Hon'ble High Court of Delhi in Subhkaran Luharuka v. State, 2010 SCC Online Del 2324, catalogued the guiding principles and procedure to be followed while dealing with an application under Section 156(3) Cr.P.C., remarking as under;
"52. ...For the guidance of subordinate courts, the procedure to be followed while dealing with an CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 17 of 27 Digitally signed by ABHISHEK ABHISHEK GOYAL GOYAL Date:
2026.05.02 16:04:36 +0530 application under Section 156(3) of the Code is summarized as under:
(i) Whenever a Magistrate is called upon to pass orders under Section 156(3) of the Code, at the outset, the Magistrate should ensure that before coming to the Court, the Complainant did approach the police officer in charge of the Police Station having jurisdiction over the area for recording the information available with him disclosing the commission of a cognizable offence by the person/persons arrayed as an accused in the Complainant. It should also be examined what action was taken by the SHO, or even by the senior officer of the Police, when approached by the Complainant under Section 156(3) of the Code.
(ii) The Magistrate should then form his own opinion whether the facts mentioned in the complaint disclose commission of cognizable offences by the accused persons arrayed in the Complaint which can be tried in his jurisdiction. He should also satisfy himself about the need for investigation by the Police in the matter. A preliminary enquiry as this is permissible even by an SHO and if no such enquiry has been done by the SHO, then it is all the more necessary for the Magistrate to consider all these factors. For that purpose, the Magistrate must apply his mind and such application of mind should be reflected in the Order passed by him.
Upon a preliminary satisfaction, unless there are exceptional circumstances to be recorded in writing, a status report by the police is to be called for before passing final orders.
(iii) The Magistrate, when approached with a Complaint under Section 200 of the Code, should invariably proceed under Chapter XV by taking cognizance of the Complaint, recording evidence and then deciding the question of issuance of process to the accused. In that case also, the Magistrate is fully entitled to postpone the process if it is felt that there is a necessity to call for a police report under Section 202 of the Code.
(iv) Of course, it is open to the Magistrate to proceed under Chapter XII of the Code when an application under Section 156(3) of the Code is also filed along with a Complaint under Section 200 of the Code if the Magistrate decides not to take cognizance of the Complaint. However, in that case, the Magistrate, before passing any order to proceed under Chapter XII, should not only satisfy himself CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 18 of 27 Digitally signed by ABHISHEK ABHISHEK GOYAL GOYAL Date:
2026.05.02 16:04:42 +0530 about the pre-requisites as aforesaid, but, additionally, he should also be satisfied that it is necessary to direct Police investigation in the matter for collection of evidence which is neither in the possession of the complainant nor can be produced by the witnesses on being summoned by the Court at the instance of complainant, and the matter is such which calls for investigation by a State agency. The Magistrate must pass an order giving cogent reasons as to why he intends to proceed under Chapter XII instead of Chapter XV of the Code..."
(Emphasis supplied)
13. Quite recently, the Hon'ble High Court of Delhi in Alok Kumar v. Harsh Mander, 2023 SCC Online Del 4213, summarized and reiterated the principles governing invocation/exercise of power/discretion under Section 156(3) Cr.P.C. as under;
"40. To summarise, a conspectus of the above- mentioned judicial precedents reveal the following:
(i) Power under Section 156(3) Cr. P.C. necessitates application of judicial mind.
(ii) Such power is to be exercised in a judicious manner, and cannot be exercised mechanically or arbitrarily.
(iii) Magistrates cannot direct registration of FIR on mere asking of complainant.
(iii) Necessity to pass Speaking Order.
41. Given that the exercise of power under Section 156 Cr.P.C. falls within the realm of judicial function rather than administrative, it necessitates the application of judicial mind. Consequently, it is incumbent upon the Magistrate to pass a reasoned order directing registration of an FIR..."
(Emphasis supplied)
14. Clearly, it is observed from above the exercise of discretion under Section 156(3) Cr.P.C. entails adoption of a cautionary approach4, with the magistrate being duty bound to 4 Kailash Vijayvargiya v. Rajlakshmi Chaudhuri, (2023) 14 SCC 1.
CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 19 of 27 Digitally signed by ABHISHEK ABHISHEK GOYAL GOYAL Date: 2026.05.02 16:04:47 +0530
pass a reasoned order, while directing registration of FIR. As aforenoted, registration of FIR cannot be directed on mere asking of complainant. On the contrary, it is only where there is substance in the complaint filed and when it appears that the allegation made therein, establish the commission of cognizable offence, requiring thorough investigation by the police, only then FIR can be ordered to be registered. Ergo, under such circumstance(s), Magistrate is required to consider the entire facts and circumstances of the case and exercise the discretion judiciously, not being unmindful of attempts to obtain such drastic orders on bald allegations and concocted stories for ulterior motives.
15. Germane for the purposes of present discourse as well as to comprehensively deal with the issue at hand to refer to the decision of the Hon'ble High Court of Delhi in Nishu Wadhwa v. Siddharth Wadhwa, 2017 SCC Online Del 6444, wherein the Hon'ble Court noted in unambiguous terms that an order dismissing or allowing an application under Section 156(3) Cr.P.C. is not an interlocutory order and a revision petition against the same is maintainable. Relevant extract(s) of the said decision are reproduced as under;
"13. The issue that since the accused has not been summoned as an accused and has no right to file a revision petition is alien, while deciding an application under Section 156(3) Cr.P.C. The said issue crops up when the Magistrate entertains the complaint and on taking cognizance proceeds as a complaint case. In case directions are issued for registration of FIR immediately, on registration of FIR, the person against whom allegations are made in the FIR attains the status of an accused. His rights in so far as the Police can summon him for investigation, arrest him without warrants for allegations of cognizable offences are duly affected. In a situation where the fundamental right of CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 20 of 27 Digitally signed by ABHISHEK ABHISHEK GOYAL GOYAL Date:
2026.05.02 16:04:53 +0530 freedom and liberty of a person is affected, it cannot be held that he has no right to be heard at that stage. Thus to hold that since directions only have been issued under Section 156(3) Cr.P.C. and no cognizance has been taken thus no revision would lie would be an erroneous reading of the decisions of the Supreme Court. Therefore, an order dismissing or allowing an application under Section 156(3) Cr.P.C. is not an interlocutory order and a revision petition against the same is maintainable."
(Emphasis supplied)
16. Consequently, in conspectus of above, further being wary of the aforenoted judicial principles, in light of the arguments addressed by the Ld. Counsel for the revisionists and by Ld. Addl. PP for the State, this Court observes that from the facts and circumstances of the case, material and the documents placed on record of this Court and the Ld. Trial Court, including inter alia the contents of the complaint as well as revisionists' entreaty seeking registration of FIR and police investigation under Section 156(3) Cr.P.C., action taken report/status report filed by/on behalf of the concerned SHO, and other documents placed on record, this Court is in concurrence with the finding of the Ld. Trial Court that there is no requirement for invocation of the provisions under Section 156(3) Cr.P.C. and/or for issuance of any direction for registration of FIR in the instant case. Needless to reiterate the identity of the accused/respondent no. 2 is already known to the revisionists; facts and allegations levelled against respondent no. 2 are already within the knowledge of the revisionists, not necessitating unearthing of any facts by means of police investigation; evidence and material of the alleged occurrence are well within the reach of the revisionists; and even the custodial interrogation of the accused/respondent no. 2, in the considered opinion of this Court, is not required at the present CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 21 of 27 Digitally signed by ABHISHEK ABHISHEK GOYAL GOYAL Date:
2026.05.02 16:04:58 +0530 case at this stage. Needless to mention that despite repeated inquiries from this Court, Ld. Counsel for the revisionists, no facts have been disclosed on which investigation is entreated in the present case, except to the extent that the FIR ought to be registered in the instant case, which, as aforenoted is not mandated under all circumstances. Apposite in the context of the foregoing to further note that the Ld. Trial Court has not dismissed the revisionists' complaint in its entirety. On the contrary, as aforenoted, by means of impugned order, Ld. Trial Court merely dismissed the revisionists' application under Section 156(3) Cr.P.C., while listing the matter for pre-summoning evidence. Accordingly, the revisionists are within his right to make out the case by leading pre-summoning evidence, with resort to the provisions under Section 202 Cr.P.C./Section 225 BNSS qua disputed facts at necessary stage, if so required.
17. Notwithstanding the foregoing, this Court deems it further pertinent to note here that neither from the contents of the complaint nor the material brought on record, the revisionists have been able to demonstrate, due compliance of the provisions under Section 154 Cr.P.C. before approaching the Ld. trial Court, with an entreaty for police investigation/registration of FIR under Section 156(3) Cr.P.C., as mandated under law. In fact, in this regard, reference is made to the decision of the Hon'ble Supreme Court in Priyanka Srivastava & Anr. v. State of U.P. & Ors., (2015) 6 SCC 287, wherein the Hon'ble Court, while explicating the necessity and mandatory nature of the compliance under Section 154 Cr.P.C. inter alia, remarked, as under;
"...30. In our considered opinion, a stage has come in this country where Section 156(3) Cr.P.C. applications are to be supported by an affidavit duly CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 22 of 27 Digitally signed by ABHISHEK ABHISHEK GOYAL GOYAL Date:
2026.05.02 16:05:03 +0530 sworn by the applicant who seeks the invocation of the jurisdiction of the Magistrate. That apart, in an appropriate case, the learned Magistrate would be well advised to verify the truth and also can verify the veracity of the allegations. This affidavit can make the applicant more responsible. We are compelled to say so as such kind of applications are being filed in a routine manner without taking any responsibility whatsoever only to harass certain persons. That apart, it becomes more disturbing and alarming when one tries to pick up people who are passing orders under a statutory provision which can be challenged under the framework of said Act or under Article 226 of the Constitution of India. But it cannot be done to take undue advantage in a criminal court as if somebody is determined to settle the scores.
32. We have already indicated that there has to be prior applications under Section 154(1) and 154(3) while filing a petition under Section 156(3). Both the aspects should be clearly spelt out in the application and necessary documents to that effect shall be filed. The warrant for giving a direction that an the application under Section 156(3) be supported by an affidavit so that the person making the application should be conscious and also endeavour to see that no false affidavit is made. It is because once an affidavit is found to be false, he will be liable for prosecution in accordance with law. This will deter him to casually invoke the authority of the Magistrate under Section 156(3). That apart, we have already stated that the veracity of the same can also be verified by the learned Magistrate, regard being had to the nature of allegations of the case. We are compelled to say so as a number of cases pertaining to fiscal sphere, matrimonial dispute/family disputes, commercial offences, medical negligence cases, corruption cases and the cases where there is abnormal delay/laches in initiating criminal prosecution, as are illustrated in Lalita Kumari are being filed. That apart, the learned Magistrate would also be aware of the delay in lodging of the FIR..."
(Emphasis supplied)
18. Correspondingly, reference is made to the recent decision of the Hon'ble Supreme Court in Ranjit Singh Bath v. State (UT of Chandigarh), 2025 SCC Online SC 1479, wherein the Hon'ble Supreme Court in an akin context, while inter alia CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 23 of 27 Digitally signed ABHISHEK by ABHISHEK GOYAL GOYAL Date: 2026.05.02 16:05:07 +0530 dismissing the direction for registration of FIR against the appellant (as before the Hon'ble Court), reiterated as under;
"7. The requirement of sub-Section (1) of Section 154 is that information regarding commission of a cognizable offence has to be furnished to an officer Incharge of a Police Station. In this case, obviously, the said compliance was not made. It is stated that the Inspector General of Police forwarded a complaint to the Economic Offences Wing. Sub- Section (3) of Section 154 comes into picture only when after a complaint is submitted to the Officer Incharge of Police Station or information is provided to the Officer Incharge of Police Station regarding commission of a cognizable offence, the Officer Incharge refuses or neglects to register First Information Report.
8. Sub-Sections (1) and (3) of Section 154 of the CrPC are the two remedies available for setting the criminal law in motion. Therefore, this Court held that before a complainant chooses to adopt a remedy under Section 156(3) of the CRPC, he must exhaust his remedies under sub-Sections (1) and (3) of Section 154 of the CRPC and he must make those averments in the complaint and produce the documents in support. However, in this case, the second respondent did not exhaust the remedies. In this view of the matter, we find that both the learned Magistrate and the High Court have completely ignored the binding decision of this Court in the case of Priyanka Srivastava.
9. We, therefore, quash and set aside both the impugned orders and quash and set aside all the further steps taken on the basis of order dated 14th June, 2017 passed by the learned Judicial Magistrate..."
(Emphasis supplied)
19. Quite evidently, it is seen from above, that the Hon'ble Supreme Court, unambiguously noted that before a complainant, opts to choose a remedy under Section 156(3) Cr.P.C., such a complainant must exhaust the remedies under sub- Sections (1) and (3) of Section 154 Cr.P.C., prior thereto. In fact, the superior courts have persistently avowed that such compliance must be made, strictly as mandated under law and that merely CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 24 of 27 Digitally signed by ABHISHEK ABHISHEK GOYAL GOYAL Date:
2026.05.02 16:05:12 +0530 endorsing a copy of application under Section 154(1) Cr.P.C. to the Superintendent of Police cannot be said to be the strict compliance of Section 154(3) of the Cr.P.C. Reference in this regard is made to the decision in Parshant Vashishta v. State of Chhattisgarh, 2023 SCC Online Chh 185, wherein the Hon'ble Chhattisgarh High Court, in an akin situation, remarked, as under;
"18. *** Registration of FIR involves serious and devastating consequences on life and liberty of a person against whom the FIR is directed to be made, therefore, strict compliance of Section 154(3) of the CrPC is required to be made which is sine qua non for maintaining an application under Section 156(3) of the CrPC and merely endorsing a copy of application under Section 154(1) of the CrPC to the Superintendent of Police cannot be said to be the strict compliance of Section 154(3) of the CrPC, there has to be a separate and independent application under Section 154(3) of the CrPC after refusal by the SHO to register FIR. Thus, there is total non-compliance of Section 154(3) of the CrPC, as no documents have been filed by the complainant in support of the averments made in paragraph 8 of the application under Section 156(3) of the CrPC..."
(Emphasis supplied)
20. Clearly, in light of the foregoing, when the material placed on record is conscientious analyzed it is noted that the revisionists marked the same complaint dated 15.09.2023, not only to the concerned SHO, PS Jama Masjid, rather, also to the concerned DCP, PS. Daya Ganj; ACP, PS. Darya Ganj; LG House; SDM, Darya Ganj; etc. on 15.09.2023, which in the considered opinion of this Court, cannot be termed as strict compliance of the provisions under Section 154 Cr.P.C. Needless to reiterate that merely endorsing a copy of application under Section 154(1) Cr.P.C. to the senior police officials, has been repeatedly avowed by superior courts to not amount to a strict compliance of Section CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 25 of 27 Digitally signed by ABHISHEK ABHISHEK GOYAL GOYAL Date:
2026.05.02 16:05:16 +0530 154(3) Cr.P.C. Rather, it has been persistently avowed that there has to be a separate and independent application under Section 154(3) Cr.P.C., after refusal by the SHO to register FIR.
21. Correspondingly, in the considered opinion of this Court, being circumspect of the facts and circumstances as well as the judicial dictates and arguments hereunder noted, registration of FIR at this stage, in the instant case, would, in the considered opinion of this Court, be against all canons of justice, both on merits, as also on non-compliance of the provisions under Section 154 Cr.P.C. Needless to reiterate that the Ld. Trial Court by impugned order, merely dismissed the revisionists' application under Section 156(3) Cr.P.C., while fixing the matter for pre- summoning evidence and in case the revisionists have a case, they can make it out by leading pre-summoning evidence.
22. Accordingly, in light of the aforesaid discussion, this Court unswervingly records and reiterates that the Ld. Trial Court did not commit any illegality and/or impropriety under the impugned order, while dismissing the revisionists' entreaty for police investigation and registration of FIR/application under Section 156(3) Cr.P.C., in light of the facts and circumstances, arguments addressed, documents and the material placed on record, as well as judicial dictates. Consequently, in the considered opinion of this Court the present revision petition deserves to be dismissed and is hereby dismissed. As a corollary, order dated 29.11.2025 passed by learned Ld. JMFC-13, Central, Tis Hazari Courts, Delhi, in case bearing, 'Richa Jain v. Sudhir Jain, Ct. Case No. 2751/2023', PS. Jama Masjid, dismissing the revisionists' application under Section 156(3) Cr.P.C., while listing the matter for pre-summoning evidence on the revisionists' CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 26 of 27 Digitally signed by ABHISHEK ABHISHEK GOYAL GOYAL Date:
2026.05.02 16:05:21 +0530 complaint is hereby upheld/affirmed. Apposite at this stage for this Court to further note that, though, it/this Court holds highest regard for the decisions relied upon by Ld. Counsel for the revisionists, however, the same would not, in the considered opinion of this Court, come to the aid/rescue of the case put forth by the revisionists in the manner as prayed for, as the facts and circumstances of the present case are clearly, distinguishable.
23. Trial Court Record along with a copy of this order/judgment be sent to the Ld. Trial Court concerned for record and information purpose(s).
24. Revision file be consigned to record room after due compliance.
Digitally signed by ABHISHEK ABHISHEK GOYAL GOYAL Date: 2026.05.02 16:05:26 +0530 Announced in the open Court (Abhishek Goyal)
on 02.05.2026. ASJ-03, Central District, Tis Hazari Courts, Delhi CR. No. 72/2026 Smt. Richa Jain & Ors. v. State (NCT of Delhi) & Ors. Page No. 27 of 27