Supreme Court: Criminal Revision Does Not End After Informant’s Death

Supreme Court: Criminal Revision Does Not End After Informant’s Death

Court clarifies law on abatement, protecting victim rights

Ruling ensures justice continues even if complainant passes away

By Our Legal Reporter

New Delhi: December 23, 2025:

In a landmark judgment delivered on December 19, 2025, the Supreme Court of India clarified that criminal revision proceedings filed by an informant or complainant do not automatically abate after their death. The Court emphasized that revisional jurisdiction is distinct from appeals, and strict rules of locus standi do not apply. This means that even if the original complainant dies, the revisional court can continue to examine the legality and correctness of the lower court’s order in the interest of justice.

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The ruling came in the case of Syed Shahnawaz Ali v. State of Madhya Pradesh & Ors., where the High Court had dismissed a criminal revision petition after the death of the informant. The Supreme Court overturned this, restoring the petition for fresh consideration.

Background of the Case

• The case originated from a complaint filed under Section 156(3) of the CrPC, leading to registration of an FIR for offences under Sections 419, 420, 467, 468, 471, 120-B, and 34 of the IPC.
• The Sessions Court discharged the accused from most charges, retaining only Section 420 (cheating).
• The informant challenged this partial discharge through a criminal revision petition.
• During the pendency of the revision, the informant died. His son, a witness in the case, sought permission to continue the proceedings.
• The High Court rejected the request, holding that revisions abate on death.
• The Supreme Court disagreed, ruling that revisions survive and can be pursued by victims or other interested parties.

Court’s Key Observations

• Revisions vs Appeals: Unlike appeals, which abate under Section 394 CrPC, revisions have no statutory provision for abatement.
• Victim rights: Victims of crime, including heirs of deceased informants, can assist the court in pursuing revisions.
• Judicial discretion: The revisional court has discretion to continue proceedings to test the correctness and legality of lower court orders.
• Balance of justice: Courts must ensure that technicalities like death of a petitioner do not obstruct justice.

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Legal Significance

• Strengthens victim rights: Families of victims can continue to seek justice even after the death of the original complainant.
• Prevents miscarriage of justice: Important cases will not be dismissed prematurely due to procedural technicalities.
• Clarifies law on abatement: Provides clear distinction between appeals (which abate) and revisions (which do not).
• Guidance for lower courts: High Courts and Sessions Courts now have clarity on handling revisions after death of informants.

Impact on Criminal Justice System

• For victims: Ensures continuity of justice and recognition of victim rights under Section 2(wa) CrPC.
• For accused: Clarifies that revisions filed by accused may abate on death, but those filed by informants survive.
• For courts: Reduces ambiguity and litigation over procedural abatement.
• For society: Reinforces faith in the justice system by prioritizing substance over technicalities.

Comparison: Appeals vs Revisions

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Expert Views

• Legal scholars say the ruling strengthens the role of victims in criminal justice.
• Advocates note that it prevents misuse of abatement rules by accused parties seeking to escape liability.
• Judicial analysts highlight that the judgment aligns with India’s evolving victim-centric approach.

Conclusion

The Supreme Court’s ruling that criminal revision does not end after the informant’s death is a milestone in India’s criminal justice system. It ensures that justice is not derailed by procedural technicalities and that victims’ families retain the right to pursue cases. By distinguishing revisions from appeals, the Court has provided clarity, strengthened victim rights, and reinforced the principle that justice must prevail over formality.

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