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According to Madhu Limaye v. State of Maharashtra (Supreme Court, 31 October 1977), how does the CrPC…

In Madhu Limaye the Supreme Court harmonised section 397(2) with section 482: the bar on revising interlocutory orders does not take away the High Court's inherent power,…

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According to Madhu Limaye v. State of Maharashtra (Supreme Court, 31 October 1977), how does the CrPC section 397(2) interlocutory-order revision bar relate to the High Court’s inherent power under section 482?

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In Madhu Limaye the Supreme Court harmonised section 397(2) with section 482: the bar on revising interlocutory orders does not take away the High Court's inherent power, but that power is used sparingly, where needed "to prevent abuse of the process" or to secure the ends of justice. It cannot be used as a routine substitute for the barred revision, nor does the bar wipe out the power where intervention is truly necessary. The corresponding provisions are now sections 438(2) and 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023.

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