Under section 419(4) of the Bharatiya Nagarik Suraksha Sanhita, 2023, from an order of acquittal by a…

Under section 419(4) of the BNSS (formerly section 378(4) CrPC), the complainant's appeal from an acquittal in a complaint case lies to the High Court after special leave. Subhash Chand rejected treating the ordinary complaint acquittal appeal as a Sessions appeal on the District Magistrate's direction (now section 419(1)(a)). The separate victim route must be distinguished.

Celestium Financial (8 April 2025) recognized that a cheque-complaint complainant who is a victim can invoke the victim-appeal proviso (now the proviso to section 413 BNSS, formerly the proviso to section 372 CrPC) without special leave. On 12 February 2026, Everest Automobiles disagreed with that interpretation and requested an authoritative larger-Bench decision, citing earlier contrary decisions. That reference order does not itself stay or overrule Celestium. The issue therefore requires this qualification, rather than an unqualified assertion that special leave is always unnecessary.