Daljit Singh Gujral & Ors vs Jagjit Singh Arora & Ors

The Supreme Court held that the summoning order under Section 202 of the Cr.P.C. was vitiated by an error apparent on the face of the record, as the complaint was filed after a considerable delay and after the Medical Board had exonerated the doctors of negligence. The Court emphasized that the principles of medical negligence must be strictly adhered to, and the complaint under Section 15 of the Indian Medical Council Act, 1956 was not maintainable. The Court quashed the summoning order and the complaint, thereby upholding the earlier High Court decision to dismiss the petition for quashing the FIR.