Adalat Prasad vs Rooplal Jindal & Ors

The Supreme Court addressed the jurisdiction of a Magistrate to recall summons issued under Section 204 of the Code of Criminal Procedure, holding that a Magistrate does not possess the power to review its own order once the summons has been issued. The Court referred to the precedent in K.M. Mathew v. State of Kerala, expressing doubt about its correctness and emphasizing that the issuance of summons is a critical step in criminal proceedings. The appeal was allowed, affirming the High Court's decision to set aside the trial court's order and remand the matter for proper disposal.