P. PHILIP vs THE DIRECTOR OF ENFORCEMENT, NEW DELHI &ANOTHER

The Supreme Court held that the term 'application' in Section 484(2)(a) of the Code of Criminal Procedure, 1973, includes a revision application under Section 435 of the old Code, thus requiring such applications pending at the time of the new Code's enactment to be disposed of under the old Code. The Court clarified that the dismissal of the revision application by the High Court was incorrect as it did not consider the saving provisions of the new Code. The appeal was allowed, and the matter was remanded for consideration under the appropriate legal framework.