JATINDER SINGH vs RANJIT KAUR

The Supreme Court held that a complaint dismissed for default can be refiled, as the dismissal was not on merits but merely for the complainant's absence. The Court emphasized that the second complaint, containing the same allegations, was maintainable and the magistrate was correct in taking cognizance of it. The ruling clarified that a dismissal in default does not bar the filing of a subsequent complaint under Section 494 IPC for bigamy and Section 109 IPC for abetment.