CRL.REV.P./419/2018 of ANAND KUMAR SINGHAL Vs CENTRAL BUREAU OF INVESTIGATION on 30 September 2026

O R D E R

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30.09.2026

1. The present revision petition has been filed under Section 401 read with Sections 482 and 483 of the Code of Criminal Procedure, 1973 (“CrPC”), seeking necessary orders and directions from this Court for quashing and setting aside of the impugned judgment dated 03rd November, 2017, passed by the Court of Special Judge-03 (PC Act)/CBI, Patiala House Courts, New Delhi (“Special Judge”).

2. Learned counsel appearing for the petitioner submits that by way of the impugned judgment, the Special Judge has convicted the petitioner for commission of offences under Section 13(1)(e) read with Section 13(2) of the Prevention of Corruption Act, 1988 (“PC Act”), and under Section 120- B read with Section 419 of the Indian Penal Code, 1860 (“IPC”).

3. This Court is informed that the petitioner has expired on 09th April,

2026.

4. A copy of the Death Certificate of the deceased-petitioner has been handed over to this Court by learned counsel appearing for the petitioner, which is taken on record.

5. This Court notes that vide the impugned judgment, the Special Judge has held as follows: “xxx xxx xxx

xxx xxx xxx

”

6. A perusal of the aforesaid judgment shows that the petitioner herein was held guilty of and convicted for offences under Section 13(1)(e) read with Section 13(2) of the PC Act, and under Section 120-B read with Section 419 of the IPC.

7. Since the petitioner has expired, he cannot be sentenced to any punishment.

8. This Court also takes note of the judgment of the Division Bench of this Court in the case of Mahender Singh Versus High Court of Delhi and Another, 2008 SCC OnLine Del 28, wherein, the Division Bench has held as follows: “xxx xxx xxx

16. The Constitution Bench in no certain terms observed that the revisional powers of the High Court vested in it by the said provision do not create any right in the litigant but only conserve the power of the High Court to see that justice is done in accordance with the recognised rules of criminal jurisdiction and that subordinate criminal courts do not exceed their jurisdiction, or abuse their powers vested in them by the court. On the other hand, it held, a right of appeal is a statutory right which has got to be recognised by the courts. For this reason, the court opined, that whereas, the Legislature has specifically provided the rules governing the right of substitution in case of death of an appellant by section 31 of the Code of 1882 (which was the provision for appeal), no such corresponding provision dealing with the question of abetment or and the right of substitution was made in a criminal revision.

xxx xxx xxx” (Emphasis Supplied)

9. As per the aforesaid judgment, the Division Bench has categorically held that no provision has been made dealing with the question of abetment or the right of substitution in a criminal revision.

10. Thus, after the expiry of the petitioner, there is no question of substitution of the legal heirs of the deceased-petitioner in the present revision proceedings.

11. Accordingly, the present petition is disposed of, noting the aforesaid.

12. All the interim orders shall stand vacated.

MINI PUSHKARNA, J SEPTEMBER 30, 2026/SK