Can the use of force by revenue officials during a statutory search be considered outside the scope of official duty for the purpose of the prior sanction rule in a revision petition before the Punjab and Haryana High Court?

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Suppose a team of officials from a statutory revenue investigation commission, accompanied by uniformed police officers, receives a warrant authorising them to enter, search, and seize records at a warehouse located in a bustling industrial area of a northern Indian city. The warrant, issued under the Revenue Investigation Act, expressly permits the officials to be assisted by police personnel. On the morning of the operation, the officials force open the main gate, break a locked storage room, and, in the process, bind the on‑site security guard with a rope and physically assault him to prevent interference. The security guard, who is a civilian employee, sustains bruises and a fractured wrist. Later that day, a senior manager of the warehouse, upon witnessing the forceful entry and the restraint of the guard, attempts to intervene and is subsequently dragged to a police vehicle, taken to the nearest police station, and subjected to further physical intimidation before being released. The manager files a First Information Report (FIR) alleging offences of voluntarily causing hurt, wrongful confinement, and criminal intimidation, naming the revenue officials and the two police officers who assisted them.

The FIR is forwarded to a local magistrate’s court, where the prosecution presents the statements of the security guard and the senior manager, along with medical certificates documenting the injuries. The accused officials invoke the requirement of prior governmental sanction under the provision that mandates sanction when a public servant is prosecuted for an act allegedly committed “while acting or purporting to act in the discharge of official duty.” The magistrate, after hearing the prosecution, decides that the alleged assaults are indeed connected with the performance of the officials’ statutory search duty and therefore dismisses the proceedings on the ground that no sanction has been obtained from the competent authority. The magistrate’s order is subsequently affirmed by the district court, which holds that the question of sanction is a jurisdictional matter that must be decided by the government, not by the courts.

The core legal problem that emerges from this factual matrix is whether the use of force against the security guard and the senior manager can be characterised as acts done “while acting or purporting to act in the discharge of official duty” for the purpose of invoking the sanction requirement. The accused contend that the force employed was excessive, unrelated to the legitimate objective of the search, and therefore should not trigger the statutory shield of Section 197 of the Code of Criminal Procedure. Conversely, the prosecution argues that any force used in the course of executing a statutory search, even if harsh, falls within the ambit of official duty, rendering prior sanction indispensable. This interpretative dispute over the scope of “official duty” and the applicability of the sanction provision is the pivotal issue that cannot be resolved merely by presenting factual defences such as denial of assault or questioning the credibility of witnesses.

Because the dispute centres on the legal classification of the officials’ conduct and the procedural requirement of governmental sanction, an ordinary factual defence at the trial stage does not provide a complete answer. The magistrate’s dismissal was predicated on a legal determination that the sanction was a pre‑condition for the court to take cognizance of the offences. Consequently, the appropriate avenue for redress lies not in contesting the evidence of assault but in challenging the legal conclusion that the sanction requirement was correctly applied. This necessitates a higher‑order review of the magistrate’s order, focusing on whether the statutory test for “official duty” was properly interpreted and whether the magistrate erred in concluding that the sanction was mandatory at that stage.

Under the hierarchy of criminal procedure, an order of a magistrate dismissing proceedings on the ground of lack of sanction is amenable to revision under the provisions that empower a High Court to examine the legality of subordinate court orders. A criminal revision petition filed before the Punjab and Haryana High Court provides the proper forum to scrutinise the magistrate’s decision, as the High Court possesses the jurisdiction to entertain revisions on questions of law and jurisdiction arising from orders of lower courts. The petition would seek quashing of the dismissal, directing the magistrate to either obtain the requisite sanction from the competent authority or to proceed with the trial if the court finds that the sanction requirement does not apply to the facts. By invoking the revisionary jurisdiction, the petitioner can obtain a definitive pronouncement on the ambit of “official duty” in the context of a statutory search, thereby resolving the procedural impasse.

In practice, a lawyer in Punjab and Haryana High Court would draft the revision petition, meticulously outlining the factual background, the statutory framework, and the divergent judicial precedents on the interpretation of Section 197. The counsel would argue that the force used was disproportionate and unrelated to the legitimate purpose of the search, citing authorities that limit the scope of “official duty” to acts that are reasonably connected to the performance of statutory functions. Simultaneously, a lawyer in Chandigarh High Court might be consulted for comparative insights, given that similar jurisprudence on sanction requirements has been developed in that jurisdiction. The involvement of lawyers in Punjab and Haryana High Court ensures that the petition adheres to the procedural requisites of filing, service, and verification, while also presenting persuasive legal arguments to persuade the bench to set aside the magistrate’s order.

Thus, the procedural solution that naturally follows from the legal problem is the filing of a criminal revision petition before the Punjab and Haryana High Court, seeking quashing of the dismissal on the ground that the sanction requirement was incorrectly applied. This remedy addresses the substantive issue of whether the alleged assaults fall within the ambit of official duty, and it provides a structured mechanism for the accused to obtain judicial clarification on the applicability of Section 197, thereby safeguarding the principles of fairness and due process in criminal proceedings.

Question: Does the use of force against the security guard and the senior manager fall within the ambit of “acting or purporting to act in the discharge of official duty” for the purpose of the sanction provision, or is it a separate unlawful act that defeats the statutory shield?

Answer: The factual matrix shows that the revenue officials entered the warehouse under a valid warrant that expressly permitted police assistance. Their primary purpose was to execute a statutory search, a function squarely within their official remit. However, the manner in which they broke the gate, forced open a locked room, bound the guard with a rope and inflicted a fractured wrist, and later dragged the senior manager to a police vehicle, raises the question of proportionality. The legal test, as articulated in precedent, requires a reasonable connection between the act and the official duty; the connection need not be perfect, but the act must be performed “in virtue of the office.” In this case, the force used to gain entry and to prevent interference can be seen as a means to facilitate the search, thereby establishing a nexus. Yet, the subsequent physical intimidation of the manager after the search was completed appears unrelated to the statutory objective and may be characterised as an independent unlawful act. Courts have drawn a line where excessive force that goes beyond what is necessary for the execution of duty loses the protection of the sanction provision. Consequently, the assault on the guard may be subsumed under the official duty because it was instrumental in gaining access, whereas the intimidation of the manager could be treated as a separate offence. This bifurcation matters because the sanction provision shields only those acts that are part of the official duty. A lawyer in Punjab and Haryana High Court would argue that the excessive nature of the force defeats the statutory shield, while the prosecution would maintain that any force employed in the course of a search, however harsh, remains within the ambit of official duty. The ultimate determination hinges on whether the court finds the connection between the force and the search to be reasonable or whether it deems the conduct a clear overstep that strips the officials of the protective sanction.

Question: Did the magistrate correctly treat the requirement of prior governmental sanction as a jurisdictional bar that precludes the court from taking cognizance, or should the issue of sanction have been examined at a later stage of the proceedings?

Answer: The magistrate’s order dismissed the FIR on the ground that no sanction had been obtained, characterising the sanction requirement as a jurisdictional prerequisite. Jurisprudence distinguishes between a jurisdictional bar, which a court cannot overlook, and a procedural requirement that may be addressed later. The sanction provision is designed to protect public servants from frivolous prosecutions, but it does not automatically strip the court of jurisdiction to entertain the complaint. Instead, the court may proceed to ascertain whether the alleged acts fall within the scope of official duty and then decide if the sanction is necessary. By treating the lack of sanction as an absolute bar, the magistrate pre‑empted any factual inquiry into the alleged assaults, effectively curtailing the prosecution’s right to present evidence. This approach conflicts with the principle that the court should first determine the existence of a prima facie case before invoking the sanction provision as a ground for dismissal. Moreover, the district court’s affirmation that the sanction issue is purely jurisdictional reinforces a rigid interpretation that may not align with established case law, which often permits the court to continue until the sanction question is finally resolved. A lawyer in Chandigarh High Court would contend that the magistrate erred by conflating a procedural safeguard with a jurisdictional limitation, thereby depriving the complainant of a fair hearing. The correct procedural route would be to allow the trial to proceed, subject to a stay or conditional order pending the government’s decision on sanction. This ensures that the factual matrix is fully explored and that the accused’s right to a fair trial is balanced against the protective intent of the sanction provision.

Question: What is the appropriate legal remedy for the accused to challenge the dismissal of the FIR, and what procedural steps must be taken to obtain relief from the Punjab and Haryana High Court?

Answer: The dismissal of the FIR on the ground of lack of sanction is amenable to revision under the provisions that empower a higher court to examine the legality of subordinate court orders. The appropriate remedy is a criminal revision petition filed before the Punjab and Haryana High Court. The petition must set out the factual background, the statutory framework, and the specific error of law alleged – namely, the erroneous classification of the sanction requirement as a jurisdictional bar. Procedurally, the petition should be verified, accompanied by copies of the FIR, the magistrate’s order, and any relevant medical reports. Service of notice to the prosecution, the investigating agency, and the competent authority responsible for granting sanction is mandatory. The petition may also seek an interim stay of the dismissal to preserve the status quo while the High Court decides the matter. In the substantive part, the petition should argue that the force used, though excessive, was connected to the official duty, and therefore the sanction provision applies, but the court should not dismiss the case before the government’s decision on sanction is obtained. Alternatively, it may contend that the acts were beyond official duty, rendering the sanction provision inapplicable, and thus the dismissal was unwarranted. A lawyer in Punjab and Haryana High Court would draft the petition, ensuring compliance with filing fees, jurisdictional thresholds, and the inclusion of precedents that support the contention. The High Court may either quash the dismissal, directing the magistrate to proceed with trial, or direct the government to consider the sanction application. If the High Court finds merit, it may also issue directions for a proper investigation. The practical implication for the accused is that the revision provides a chance to have the case heard on its merits, while the complainant gains an opportunity to pursue the alleged offences without premature dismissal.

Question: How does the participation of police officers in the forced entry and subsequent intimidation affect the applicability of the sanction provision to both the revenue officials and the police, and what are the potential consequences for each party?

Answer: The involvement of police officers adds a layer of complexity to the analysis of the sanction provision. The provision applies to public servants acting in the discharge of official duty, and police officers, as agents of the state, fall within its ambit when they assist in executing a statutory search. The warrant expressly permitted police assistance, thereby integrating the officers into the official operation. Consequently, any acts they commit in furtherance of the search, such as breaking the gate or restraining the guard, are likely to be viewed as performed “while acting or purporting to act in the discharge of official duty.” However, the subsequent intimidation of the senior manager, which occurred after the search had been completed, may be deemed an act beyond the scope of the authorized function. If the court determines that the police officers exceeded the limits of their official role, the sanction provision would not shield them, exposing them to direct criminal liability. For the revenue officials, the same analysis applies: the force used to gain entry may be protected, but any excessive or unrelated intimidation could strip them of the statutory shield. The practical consequence is that the sanction provision may bar prosecution only for those acts that are closely linked to the execution of the search. Any acts deemed extraneous will render the accused vulnerable to prosecution without the need for prior governmental sanction. A lawyer in Chandigarh High Court would argue that the police officers’ participation does not automatically immunise them from liability for the manager’s intimidation, while a lawyer in Punjab and Haryana High Court would emphasize the need for a nuanced assessment of each act’s connection to official duty. Ultimately, the court’s determination will dictate whether the sanction provision applies to both parties for the entire conduct or only for the portion directly related to the authorized search.

Question: On what legal basis can the accused officials seek a criminal revision of the magistrate’s dismissal of the FIR before the Punjab and Haryana High Court, and why is this forum appropriate for reviewing the sanction issue?

Answer: The accused officials can invoke the revisionary jurisdiction vested in the Punjab and Haryana High Court to challenge the magistrate’s order dismissing the FIR on the ground of lack of governmental sanction. Under the hierarchy of criminal procedure, a revision petition is the correct remedy when a subordinate court’s order appears to be illegal, erroneous, or made without jurisdiction, particularly on questions of law. The magistrate’s decision rested on a legal interpretation of the sanction provision, concluding that the alleged assaults were performed while acting in the discharge of official duty and therefore required prior approval from the competent authority. This determination is not a factual assessment of the injuries or the credibility of witnesses; it is a question of statutory construction and the scope of official duty. Because the High Court possesses the authority to examine whether the lower court correctly applied the law and whether it erred in treating the sanction requirement as a jurisdictional bar, the revision petition is the appropriate vehicle. The Punjab and Haryana High Court’s territorial jurisdiction covers the district where the warehouse is situated, and it has the power to entertain revisions arising from orders of magistrates and district courts within its territorial limits. By filing a revision, the accused can request the High Court to either quash the dismissal and direct the magistrate to proceed with the trial, or to direct the government to consider granting the sanction if the court finds the sanction provision applicable. The procedural route ensures that the legal question is resolved by a higher judicial authority before any further evidentiary proceedings, thereby preserving the rights of the accused against premature termination of the case. In preparing the petition, the accused would typically engage a lawyer in Punjab and Haryana High Court who is versed in criminal revision practice, ensuring that the pleading complies with the High Court’s rules of form, service, and verification.

Question: Why does a factual defence based solely on denying the assault or questioning the witnesses’ credibility fail to address the core issue in the present stage of proceedings?

Answer: At the stage where the magistrate dismissed the FIR, the core issue is not whether the accused actually inflicted injuries or whether the witnesses are reliable; rather, it is whether the alleged conduct falls within the ambit of the sanction provision that shields public servants from prosecution absent prior governmental approval. The magistrate’s order was premised on a legal conclusion that the force used was part of the execution of a statutory search, thereby invoking the sanction requirement. Consequently, any factual defence that merely contests the occurrence of the assault or the extent of the injuries does not engage with the pivotal legal question of “official duty.” The law demands that the court first determine whether the conduct can be legally characterized as performed in the discharge of official duty before it can even entertain evidence on the merits. This hierarchical approach ensures that the protection afforded to public officials is not circumvented by factual disputes that could be resolved only after the sanction issue is settled. Moreover, the prosecution’s case is built upon the premise that the officials acted under the authority of a warrant, and the magistrate’s dismissal effectively barred the trial on procedural grounds. Therefore, a factual defence would be premature and ineffective until the High Court either confirms that the sanction provision applies, thereby requiring the government’s approval, or holds that the conduct lies outside the scope of official duty, allowing the trial to proceed. Engaging a lawyer in Chandigarh High Court for comparative jurisprudence can help the accused understand how other jurisdictions have treated similar factual defences in the context of sanction disputes, but the decisive factor remains the legal interpretation of the sanction provision, not the factual narrative.

Question: How does the jurisdiction of the Punjab and Haryana High Court extend to this case, considering the location of the warehouse, the investigating agency, and the nature of the alleged offences?

Answer: The Punjab and Haryana High Court’s territorial jurisdiction encompasses the district where the warehouse is situated, as well as the administrative reach of the statutory revenue investigation commission that authorized the search. The investigating agency, being a statutory body operating under the revenue investigation framework, is empowered to conduct searches throughout the state, and its officers are deemed public servants for the purposes of the sanction provision. Because the alleged offences—voluntarily causing hurt, wrongful confinement, and criminal intimidation—were committed within the geographical limits of the High Court’s jurisdiction, any criminal proceeding arising from those acts falls under its supervisory authority. Additionally, the High Court has the power to entertain revisions of orders passed by subordinate courts within its territorial ambit, irrespective of whether the case involves civil or criminal matters. The nature of the offences, being cognizable and non‑bailable, further underscores the necessity of a higher judicial review to ensure that the procedural safeguards afforded to accused public servants are correctly applied. The High Court’s jurisdiction also includes the authority to direct the government to grant or refuse the sanction, a function that lower courts cannot perform. Consequently, the accused must approach the Punjab and Haryana High Court to obtain a definitive ruling on whether the sanction provision applies, thereby determining the continuance of the criminal proceedings. In navigating this jurisdictional landscape, the accused may seek counsel from lawyers in Punjab and Haryana High Court who possess experience in handling revision petitions involving public servants, ensuring that the petition is framed in accordance with the High Court’s procedural requisites and substantive jurisprudence.

Question: What procedural steps must the accused follow in drafting and filing a criminal revision petition, and why might they also consult a lawyer in Chandigarh High Court for strategic insights?

Answer: The procedural roadmap begins with the preparation of a revision petition that succinctly sets out the factual background, the operative order of the magistrate, and the specific grounds on which the order is challenged. The petition must articulate that the magistrate erred in law by treating the sanction requirement as a jurisdictional bar without proper interpretation of the sanction provision. It should include a prayer for the High Court to quash the dismissal, direct the magistrate to either obtain the requisite governmental sanction or to proceed with trial if the sanction is deemed inapplicable. The petition must be verified, signed, and accompanied by a copy of the magistrate’s order, the FIR, and any relevant documents such as medical certificates. Service of notice to the prosecution, the investigating agency, and the government department authorized to grant sanction is mandatory, ensuring that all parties are apprised of the proceedings. The filing fee must be paid, and the petition must be filed within the prescribed period from the date of the magistrate’s order. While the primary forum is the Punjab and Haryana High Court, consulting a lawyer in Chandigarh High Court can be strategically valuable because that court has developed nuanced jurisprudence on the interplay between sanction provisions and the rights of accused public servants. Comparative insights from Chandigarh High Court decisions may bolster the arguments, especially where the Punjab and Haryana High Court has previously followed similar reasoning. Engaging a lawyer in Chandigarh High Court, or at least reviewing its judgments, can help the accused craft persuasive submissions that align with prevailing judicial trends, thereby enhancing the prospects of a favorable revisionary outcome.

Question: What are the potential outcomes of a successful revision petition before the Punjab and Haryana High Court, and how would each outcome affect the continuation of the criminal proceedings against the accused?

Answer: A successful revision petition can lead to one of several consequential outcomes. The High Court may quash the magistrate’s dismissal and direct the magistrate to proceed with the trial without obtaining prior governmental sanction, thereby allowing the prosecution to present its evidence on the alleged assault, confinement, and intimidation. In this scenario, the accused would face the full spectrum of procedural safeguards at trial, including the opportunity to challenge the prosecution’s evidence, cross‑examine witnesses, and raise any applicable defences. Alternatively, the High Court may direct the competent government authority to consider granting the sanction, effectively pausing the criminal proceedings until the sanction decision is rendered. If the government subsequently refuses sanction, the proceedings would terminate, resulting in a de‑facto acquittal of the accused on the basis that the sanction provision bars prosecution. Conversely, if the government grants sanction, the case would resume, and the magistrate would be required to take cognizance and conduct a trial. A third possible outcome is that the High Court may find that the conduct falls outside the ambit of official duty, thereby holding that the sanction provision does not apply. In that event, the magistrate would be ordered to proceed with the trial irrespective of any governmental sanction, and the accused would be subject to the ordinary criminal process. Each of these outcomes reshapes the procedural posture of the case: either advancing it to trial, suspending it pending a governmental decision, or terminating it altogether. The accused must therefore be prepared for any of these eventualities, and the strategic counsel of lawyers in Punjab and Haryana High Court is essential to navigate the subsequent steps, whether that involves preparing for trial, filing further applications for bail, or seeking a review of the sanction decision if it is adverse.

Question: How can the accused officials contest the magistrate’s reliance on the prior‑sanction rule when the force used during the search appears excessive and unrelated to the statutory purpose of the warrant?

Answer: The accused must first demonstrate that the acts of binding the security guard and dragging the senior manager to a police vehicle exceed the scope of conduct that can be characterised as performed “while acting or purporting to act in the discharge of official duty.” The legal test requires a reasonable connection between the act and the official function; however, the factual matrix shows that the officials broke a locked storage room, used physical restraint, and inflicted injuries that were not necessary to preserve evidence or prevent escape. A lawyer in Punjab and Haryana High Court would argue that the excessive force transforms a lawful search into an unlawful assault, thereby breaking the causal link required for the sanction provision to apply. The argument would be supported by precedents where courts have held that acts of violence unrelated to the execution of statutory powers fall outside the protective umbrella of official duty. By filing a criminal revision petition, the accused can seek a declaration that the magistrate erred in treating the conduct as protected, and that the requirement of prior governmental sanction should not have been invoked at the stage of dismissal. The petition would request that the High Court set aside the dismissal, direct the magistrate to take cognizance of the offences, and allow the prosecution to proceed without the sanction. Practically, this strategy shifts the burden onto the government to either grant sanction, which is unlikely given the evident excess, or to accept that the acts are not covered by the official‑duty exception. If successful, the accused would face trial on the substantive charges, but would have avoided the procedural bar that currently shields them. The approach also preserves the possibility of negotiating a settlement or mitigating penalties once the matter is before a trial court, rather than being prematurely extinguished by a jurisdictional error.

Question: Which documentary and medical evidences are essential for establishing the nature and severity of the injuries inflicted, and how can they be used to rebut the claim that the conduct was a lawful component of the search?

Answer: The prosecution’s case hinges on the FIR, the statements of the security guard and the senior manager, and the accompanying medical certificates documenting bruises and a fractured wrist. A lawyer in Punjab and Haryana High Court would advise the accused to obtain certified copies of the medical reports, radiographic images, and the attending physicians’ opinions that describe the mechanism of injury, emphasizing that the trauma resulted from deliberate restraint rather than accidental harm. Additionally, the original search warrant, the police assistance order, and any after‑action reports prepared by the revenue officials are critical to show the intended scope of the operation. By juxtaposing the medical evidence with the warrant’s limited purpose—seizure of records—the defence can argue that the injuries were disproportionate and unrelated to preserving evidence. The guard’s statement, if it details the use of a rope and the forceful opening of the locked room, further illustrates an overreach. The senior manager’s testimony about being dragged to a police vehicle and subjected to intimidation adds to the narrative of unlawful conduct. These documents can be filed as annexures to the revision petition to demonstrate that the factual matrix supports a conclusion that the acts were not incidental to the search. Moreover, the defence may request an independent forensic examination to corroborate the injuries’ cause, thereby strengthening the argument that the conduct was punitive rather than procedural. The inclusion of these evidentiary materials not only undermines the magistrate’s finding of a lawful connection but also prepares the ground for a robust defence at trial, should the High Court allow the proceedings to continue. By meticulously assembling the documentary trail, the accused can show that the alleged offences are distinct from any legitimate official function.

Question: What procedural irregularities arise from the magistrate’s determination that the sanction issue is purely jurisdictional, and how should a revision petition be structured to compel the High Court to re‑examine the legal test for “official duty”?

Answer: The primary procedural defect is the magistrate’s pre‑emptive dismissal of the case on the ground that the sanction requirement is a jurisdictional matter reserved for the government, without first assessing whether the alleged acts fall within the ambit of official duty. This bypasses the established principle that courts must first determine the existence of a prima‑facie connection before invoking the sanction bar. A lawyer in Punjab and Haryana High Court would craft the revision petition to highlight this error, citing the need for a two‑stage analysis: first, whether the conduct is connected to the statutory function, and second, whether the sanction has been obtained. The petition should set out the factual background, attach the FIR, medical certificates, and the search warrant, and argue that the magistrate erred in law by treating the sanction issue as a jurisdictional bar at the dismissal stage. It must request that the High Court examine the legal test for “official duty,” applying the established jurisprudence that requires a reasonable connection, not merely a formal link. The petition should also point out that the magistrate’s order deprives the complainants of a fair opportunity to have their grievances heard, violating principles of natural justice. By seeking a quashing of the dismissal and an order directing the magistrate to proceed with trial or to seek sanction, the revision petition forces the High Court to address the substantive legal question. Additionally, the petition can ask the High Court to issue a direction for the investigating agency to produce a detailed report on the necessity of the force used, thereby creating a factual record for the court’s consideration. This structured approach ensures that the High Court’s review is not limited to a procedural technicality but engages with the core issue of whether the accused’s conduct can be protected by the official‑duty exception.

Question: Considering the serious allegations and the current custodial status of the accused, how can the defence mitigate the risk of prolonged detention and secure bail while the revision petition is pending?

Answer: The defence should promptly file an application for bail, emphasizing that the allegations, while grave, do not warrant continued incarceration in the absence of a conviction or a finding that the accused are a flight risk. A lawyer in Chandigarh High Court would argue that the accused have cooperated with the investigating agency, that the medical evidence shows injuries inflicted by the officials, and that the primary dispute is a legal question of sanction, not factual guilt. The bail application must highlight the lack of a substantive trial, the pending revision before the Punjab and Haryana High Court, and the principle that bail is the rule, imprisonment the exception. It should also request that the accused be released on personal bond with conditions such as surrendering passports, regular reporting to the police station, and refraining from interfering with witnesses. The defence can further submit affidavits from the accused’s family and employer attesting to their ties to the community, thereby reducing the perceived flight risk. By underscoring that the High Court’s decision on the revision could potentially overturn the dismissal and that the accused are prepared to face trial, the application presents a balanced view of the interests of justice. Additionally, the defence may seek a direction for the investigating agency to file a status report on the sanction issue, which would provide the court with a clearer picture of the procedural posture. If bail is granted, the accused can continue to assist in the preparation of the revision petition, ensuring that their defence remains robust while they remain out of custody, thereby preserving their liberty and mitigating the personal and professional repercussions of prolonged detention.