S. Reddappa vs Sri Vijaya M. on 7 August, 1996
In Gautam Ranjan Basu v. Smt. Shanta Mukherjee, 1995 Cri LJ 1131, learned single Judge of the Calcutta High Court has said that in case of demise of the complainant there cannot be any ipso facto termination of the criminal proceedings, Magistrate has every power to allow substitution upon the demise of the original complainant if he is satisfied from the other surrounding circumstances and materials on record that such permission should be given, that satisfaction is to be subjective satisfaction derived from the records of the case and a satisfaction derived on fact available on record.