SUBRATA DAS vs STATE OF JHARKHAND

The Supreme Court upheld the dismissal of a petition under Section 482 Cr.P.C. challenging the issuance of summons against the appellant for offences under Sections 341, 323, 506 IPC and Sections 3(i)(x) and 2(vii) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989. The Court found that two lower courts had established a prima facie case against the appellant, and the High Court's decision to not quash the proceedings was affirmed. The ruling clarified the scope of review under Section 398 Cr.P.C. and confirmed the legal validity of the lower courts' findings.