Shakuntala Devi & Ors vs Chamru Mahto & Anr

The Supreme Court held that the Patna High Court erred in entertaining a second revision application under Section 397(3) of the Code of Criminal Procedure, 1973, which prohibits such revisions. The Court emphasized that the inherent powers under Section 482 cannot be invoked to bypass statutory limitations. Consequently, the order of the Patna High Court was quashed, and the orders of the Sub-Divisional Magistrate and the Additional Sessions Judge were restored, affirming the appellants' possession of the disputed land.