SMT. NAGAWWA vs VEERANNA SHIVALlNGAPPA KONJALGI

The Supreme Court held that the High Court erred in reviewing the Magistrate's order under Section 204(1)(b) of the Code of Criminal Procedure, 1973, by examining merits and documents not part of the original complaint. The Court established that the scope of inquiry under Section 202 is limited to determining if a prima facie case exists based solely on the complaint's allegations. The appeal was allowed, and the High Court's order was set aside, reaffirming that the accused has no locus standi at this stage.