JAMUNA SINGH AND OTHERS vs BHADAI SAH

The Supreme Court held that when a Magistrate examines a complaint under Section 200 of the Code of Criminal Procedure, he is deemed to have taken cognizance of the offences mentioned therein. The Court clarified that the Magistrate's order for police investigation should be interpreted as an action under Section 202, not Section 156(3), thus affirming that the case was instituted on complaint rather than a police report. Consequently, the appeal under Section 417(3) was valid, and the High Court's conviction under Section 395 IPC was upheld.