Does the High Court’s Dismissal of a Criminal Revision as Infructuous Create Any Precedential Value on Substantive Legal Questions?

Where a criminal revision is dismissed as infructuous following withdrawal of the underlying proceedings, the judgment does not decide any substantive question of law and does not add to or change existing precedent. Such decisions are of no binding or persuasive authority on legal questions for future cases.

 

Summary

Category Data
Case Name CRR/686/2024 of AMRITA DAS PATTANAYAK (NEE BAG) Vs SANJIB DAS PATTANAYAK
CNR WBCHCA0082552024
Date of Registration 16-02-2024
Decision Date 29-10-2025
Disposal Nature DISMISSED AS WITHDRAWN
Judgment Author HON’BLE JUSTICE BIBHAS RANJAN DE

Practical Impact

Category Impact
Binding On None
Persuasive For None

What’s New / What Lawyers Should Note

  • The High Court dismissed the revision as infructuous, as the underlying proceeding had already been withdrawn before the subordinate magistrate.
  • No substantive legal issue or principle was adjudicated.
  • Such dismissals do not create any binding or persuasive authority and are irrelevant for citation on legal propositions.

Summary of Legal Reasoning

  • Both counsels informed the Court that the proceeding in question had already been withdrawn and the Learned Additional Chief Judicial Magistrate had dismissed it as withdrawn.
  • The Court took the certified copy of the order of withdrawal on record.
  • On this basis, the High Court held the revision application to be infructuous and dismissed it accordingly.
  • No legal question was addressed or decided, and no reasoning on the merits of the dispute was provided.

Arguments by the Parties

Petitioner

  • Submitted that the proceeding which was the subject of the revision application had already been withdrawn.

Respondent

  • Concurred that the proceeding before the subordinate magistrate had been withdrawn and endorsed dismissal as infructuous.

Factual Background

Both parties attended before the High Court. Their counsels confirmed that the criminal proceeding underlying CRR 686 of 2024 had already been withdrawn before the Learned Additional Chief Judicial Magistrate, who dismissed it as withdrawn. The High Court noted the certified copy of this withdrawal order and, accordingly, found the present revision to be infructuous.

Statutory Analysis

No statutory provisions were analyzed or interpreted in the order. The Court proceeded solely on the basis of the factual withdrawal of the proceeding.

Dissenting / Concurring Opinion Summary

No dissenting or concurring opinions are recorded in the judgment.

Procedural Innovations

No procedural precedents or innovations were set by this order.

Alert Indicators

  • ✔ Precedent Followed – The Court followed existing procedure in dismissing the revision as infructuous due to withdrawal of the underlying proceeding. No substantive precedent was set or changed.

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