Summary: (a) Constitution of Pakistan ----Art. 199---Constitutional jurisdiction---Maintainability---Alternative remedy---Petitions under Art. 199 for quashment of FIRs and orders under S. 249-A, Cr.P.C.—Scope---Where statutory remedy of revision existed and no constitutional right was infringed, extraordinary jurisdiction could not be invoked merely to circumvent the regular criminal process—However, Court examined legality as petitions were consolidated and involved identical legal questions. (b) Criminal Procedure Code (V of 1898) ----Ss. 561-A, 249-A & 403—Quashment of FIRs—Double jeopardy—Dishonoured cheques issued on different dates---Distinct transactions---Held, each dishonour arising from separate cheque constitutes a separate cause of action and distinct offence; multiple FIRs, each based on an independently dishonoured cheque, do not attract the bar of S. 403, Cr.P.C. or Art. 13 of the Constitution---Petitioner’s plea that subsequent FIRs were hit by double jeopardy was misconceived—No illegality in dismissal of S. 249-A applications by trial and revisional courts. Cited Cases: • *Saira Fatima v. The State* (2024 P Cr.LJ 1289) • *State v. Saeed Khan* (2021 P Cr.LJ 608) (c) Criminal Procedure Code (V of 1898) ----S. 234—Joinder of charges—Dishonour of cheques within twelve months—Discretion of trial court---Where several offences of the same kind are alleged within one year, trial court may, on request, join them in a single trial to prevent multiplicity of proceedings. (d) Criminal Procedure Code (V of 1898) ----Ss. 503 & 539-B—Recording of complainant’s statement through local commission---Legality---Where complainant’s physical appearance before court was impracticable due to health or security concerns, trial court may appoint an advocate-commissioner to record evidence at residence—No prejudice caused to accused if attendance is already dispensed with—Order modifying mode of recording evidence held lawful and within discretion of trial court. (e) Penal Code (XLV of 1860) ----S. 489-F—Dishonoured cheque—Successive prosecutions---Separate FIRs for distinct cheques dishonoured on different dates do not offend double jeopardy principles; each dishonour gives rise to a fresh and independent offence. (f) Criminal Justice—Quashment proceedings ----Jurisdiction under S. 561-A Cr.P.C.—Parameters—Only exercisable where continuation of proceedings is manifestly illegal, oppressive, or amounts to abuse of process—Mere existence of multiple FIRs for separate transactions or pendency of trial does not justify quashment. Disposition --- All petitions dismissed. Orders dated 20-07-2022 (refusing acquittal under S. 249-A), 15-10-2022 (revisional order), 10-06-2023 (appointment of local commission), and 26-08-2023 (revisional confirmation) upheld. Trial court directed to ensure police security during recording of complainant’s statement at his residence. No order as to costs.

Summary: (a) Criminal Procedure Code (V of 1898)--- ----S. 476---Power of Court to initiate proceedings for offences committed in relation to judicial proceedings---Scope and object---Purpose of S.476, Cr.P.C is to preserve the sanctity and dignity of the judicial process by empowering Courts to take action against those who give false evidence, submit forged documents, or otherwise abuse the process of law---Said power extends to civil, criminal and revenue Courts in respect of offences enumerated in Ss.193 to 196, 199 to 200, 205 to 211 and 228, P.P.C---Before initiating such proceedings, the Court is bound to hold a fair preliminary inquiry and provide opportunity of hearing to the accused in accordance with principles of natural justice---Failure to conduct such inquiry or to afford hearing renders the proceedings illegal and violative of due process of law---Reference made to Qazi Naveed ul Islam v. District Judge Gujrat (PLD 2023 SC 298) and Abdul Hakeem v. The State (1994 SCMR 1103). (b) ---Revisional jurisdiction---Exercise of power by Revisional Court under S. 435, Cr.P.C---Revisional Court had lawfully exercised its authority in remanding matter to Magistrate for proper inquiry under S.476, Cr.P.C---Revisional Court had neither exceeded its jurisdiction nor committed any illegality or irregularity---Order passed in accordance with law and procedural fairness---No ground for interference in constitutional jurisdiction of High Court. (c) Constitution of Pakistan, 1973--- ----Arts. 10-A & 13---Due process and protection against double punishment---Contention that passing of Impugned Order amounted to double punishment after imposition of costs at time of withdrawal of civil suit, held to be misconceived---Imposition of costs by Civil Court was civil in nature while direction for inquiry under S.476, Cr.P.C pertained to criminal liability for false verification and perjury---Two operate in distinct legal spheres and do not constitute double jeopardy---No violation of Arts.10-A or 13 of the Constitution made out. Petition dismissed.