Chand Devi Daga . vs Manju K. Humatani .

The Supreme Court upheld the High Court's decision allowing the legal representatives of the deceased complainant to substitute her in prosecuting a criminal complaint under Sections 420, 467, 468, 471, 120B, 201, and 34 IPC. The Court clarified that the absence of a specific provision in the Code of Criminal Procedure, 1973 does not preclude legal heirs from pursuing the case after the complainant's death. The appeal was dismissed, affirming the High Court's jurisdiction to permit such substitution.