A.K. SUBBAIAH & ORS. vs STATE OF KARNATAKA & ORS.

The Supreme Court upheld the High Court's decision to delete the names of the Director General of Police and the Chief Minister from the revision petition under Sections 397 and 401 of the Criminal Procedure Code (Cr.P.C.). The Court clarified that in a revision against the issue of process, the High Court's role is limited to determining whether the complaint and accompanying papers prima facie indicate an offence. It emphasized that Section 401(2) Cr.P.C. does not require the inclusion of parties who were not involved in the trial court proceedings, affirming the High Court's jurisdictional limits.