Shailabala Devi vs Emperor on 18 August, 1933
In Shailabala Devi v. Emperor, AIR 1933 All 678, it was held by a Full Bench of this Court that only a party to the proceedings in the inferior Criminal Court can make an application under Section 435, that a stranger to the proceedings cannot make any application under Section 435, that an application made by a stranger may, however, be treated as information, and the High Court or the Sessions Judge or the District Magistrate may act upon it and that though no revision application has been filed by the aggrieved party, who could have appealed but has not, (on account of the bar imposed by Sub-section (5)), the High Court can act on the information received and revise the order.