SHEO NANDAN PASWAN vs STATE OF BIHAR & ORS.

The Supreme Court examined the scope of Section 321 of the Code of Criminal Procedure, 1973, regarding the Public Prosecutor's power to withdraw from prosecution and the Magistrate's consent. It held that a complainant has locus standi to file a revision before the High Court and an appeal under Article 136 against an order granting consent to withdraw a criminal case. The Court clarified that 'discharge' under Section 321 differs from discharge under Sections 227 or 239, emphasizing the need for an error apparent on the face of the record for review under Article 137 of the Constitution.