BINDESI-IWARI PRASAD SINGH vs KALI SINGH

The Supreme Court held that the Sub-Divisional Magistrate acted improperly by failing to address a trivial complaint under Section 95 IPC, which did not warrant criminal proceedings. The Court emphasized that the Magistrate's prolonged inaction and failure to apply his mind led to unnecessary delays, ultimately dismissing the complaint under Section 203 of the Code of Criminal Procedure, 1973. The Court ruled that the Magistrate lacked jurisdiction to recall the dismissal order without a formal order, thereby reinforcing the need for judicial diligence in handling complaints.