Delhi High Court Dismisses Frivolous Petition Seeking FIR Registration With Costs, Refuses to Override Second Revision Bar

Case Snapshot

• Case Name: Exclusive Capital Limited v. State Govt of NCT Delhi & Ors.

• Citation: CRL.M.C. 130/2026 (2026:DHC:6742)

• High Court: High Court of Delhi

• Bench: Hon'ble Mr. Justice Girish Kathpalia

• Date of Judgment: 17th August, 2026

• Area of Law: Criminal Procedure, FIR Registration, Revision, Inherent Powers

Judgment Headline

Court dismisses second revision attempt with costs, holds inherent powers cannot circumvent statutory bar.

The Judgment in One Line

Delhi High Court dismissed petition seeking FIR registration, holding inherent powers cannot give backdoor entry to barred second revision.

Why This Judgment Matters

This landmark judgment clarifies the interplay between Section 438(3) BNSS (bar on second revision) and Section 528 BNSS (inherent powers). It establishes that while inherent powers exist to prevent abuse of process, they cannot be invoked in routine manner to circumvent the explicit prohibition on second revisions. The Court laid down that inherent powers may be exercised only in "rarest of rare cases" of gross injustice or miscarriage of justice where the litigant is rendered completely remediless. The ruling protects the integrity of the revision scheme and prevents frivolous litigation from clogging the judicial system.

Background

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