VIVEK RAI & ANR. vs HIGH COURT OF JHARKHAND THR.REG.GEN & OR

The Supreme Court held that Rule 159 of the High Court of Jharkhand Rules, 2001, which mandates that a petitioner must surrender to custody before a revision petition under Sections 397 and 401 of the Cr.P.C. can be admitted, is not violative of Articles 14 and 21 of the Constitution. The Court emphasized that subordinate legislation can set procedural requirements that do not conflict with substantive statutory provisions. The petitioners' challenge to the validity of the Rule was dismissed, affirming the High Court's authority to regulate its procedures.