State Of U.P vs Suresh Chandra Srivastava & Ors on 3 May, 1984
In Ajit Narayan Haskar v/s. State (supra), complainant initially
filed a complaint against two accused persons, accordingly they were
summoned by the Court. However, later on complainant filed a
supplementary complaint under Section 200 Cr.P.C against as many as 21
persons. Accordingly, Court also summoned them. The said order was
challenged before the High Court of Karnataka (Bangalore Bench) and a
question arose whether supplementary complaint can be filed in complaint
case or not? Para No. 5 of the judgment is relevant and the same is
reproduced as under: