When Does a Criminal Revision Abate on the Death of the Petitioner? Clarification on Abatement and Dismissal Procedure by the High Court

The High Court holds that a criminal revision abates upon the death of the petitioner and must be dismissed accordingly; affirms established procedural law and does not overrule or modify any precedent; practical utility is limited as the order is not approved for reporting.

 

Summary

Category Data
Case Name CR.R/73/2015 of SHAMBU DAYAL SIDHU Vs AMAR CHAND
CNR HPHC010065572015
Date of Registration 20-03-2015
Decision Date 30-10-2025
Disposal Nature Abated
Judgment Author HON’BLE MR. JUSTICE RAKESH KAINTHLA
Court High Court of Himachal Pradesh
Bench Single Judge (Hon’ble Mr. Justice Rakesh Kainthla)
Precedent Value Not approved for reporting
Type of Law Criminal Procedural Law
Ratio Decidendi
  • The criminal revision proceedings abate on the death of the petitioner.
  • Upon intimation of death, the proceedings are dismissed as abated, including any pending miscellaneous applications.
  • This approach follows established procedural practice regarding abatement.
  • The court’s decision does not set a binding or persuasive precedent, as it is not approved for reporting.

Practical Impact

Category Impact
Binding On Not binding, as the judgment is not approved for reporting.

What’s New / What Lawyers Should Note

  • The judgment reiterates that upon the death of the petitioner in criminal revision proceedings, the matter abates and should be dismissed as such.
  • The decision is explicitly not approved for reporting, highlighting it lacks precedential value for future reference.

Summary of Legal Reasoning

  • The court records the submission that the petitioner has expired.
  • Based on this, the court holds that the criminal revision stands abated against the deceased petitioner.
  • Consequently, the criminal revision petition and any pending miscellaneous applications are dismissed as abated.
  • The court follows standard procedural rules about abatement in criminal revision proceedings and does not issue any new interpretation or substantive finding.

Arguments by the Parties

Petitioner

  • Counsel submitted that the petitioner had expired, and therefore, the proceedings should abate.

Respondent

  • No submissions recorded in the judgment.

Factual Background

The criminal revision was pending before the High Court of Himachal Pradesh. During its course, it was brought to the Court’s notice that the petitioner had expired. In light of this, the petitioner’s counsel applied for the proceedings to be abated.

Statutory Analysis

  • The judgment does not discuss or interpret any statutory provision in detail.
  • Procedural abatement is recognized in criminal law practice upon the death of the petitioner.

Dissenting / Concurring Opinion Summary

No concurring or dissenting opinions are recorded in this judgment.

Procedural Innovations

No procedural innovations or new guidelines are introduced in this decision.

Alert Indicators

  • Precedent Followed — The judgment applies established procedural law regarding abatement, with no departure from precedent.

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