Dilip Kumar vs Brajraj Shrivastava

The Supreme Court examined whether the Magistrate's order dismissing the complaint under Section 203 of the Cr.P.C. was justified, given that the Magistrate had initially intended to hold an inquiry under Section 202 but only recorded the statement of the complainant before dismissing the complaint. The High Court had interfered with this order, but the Supreme Court clarified the procedural requirements for such inquiries and dismissals. The Court upheld the Magistrate's order, emphasizing the importance of proper inquiry procedures before dismissing a complaint in criminal proceedings.