THE STATE OF KERALA vs NARAYANI AMMA KAMALA DEVI

The Supreme Court held that the High Court can exercise its revisional jurisdiction under Section 439 of the Code of Criminal Procedure, 1898, even after the death of the accused. The Court distinguished between appellate and revisional jurisdiction, noting that while appellate jurisdiction requires an appeal to be filed by the convicted person, there is no such limitation for revisional jurisdiction. The High Court's decision to entertain the revision petition filed by the deceased's family was upheld, affirming that the revision can be initiated by any person or even suo motu by the High Court based on its own knowledge.