High Court of Gujarat

VISHAL CHANDUBHAI UMRANIYAversusSTATE OF GUJARAT

Disposal: 98-DISPOSED AS ABATED
Bench: HASMUKH D SUTHAR

Holding

The death of the applicant pending the revision proceedings results in the abatement of the applications, leading to their disposal.

Summary

The applicant, Vishal Chandubhai Umraniya, filed criminal revision applications challenging his conviction under the Negotiable Instruments Act. While these applications were pending, the applicant died on 23 May 2024, and a death certificate was placed on record. The court considered whether the pending revision applications could continue after the death of the applicant. It held that the death of the applicant extinguishes his right to seek revision, causing the applications to abate. Consequently, the court discharged the rule and vacated any interim relief, disposing of the revision applications as abated.

Issues considered

What is the effect of the death of a litigant on pending criminal revision applications?

Subjects

criminal revisionabated proceedingsdeath of litigantNegotiable Instruments Acthigh court order

Judgment

        R/CR.RA/50/2018                                                          ORDER DATED: 07/04/2026




 IN THE HIGH COURT OF GUJARAT AT AHMEDABAD
   R/CRIMINAL REVISION APPLICATION (AGAINST CONVICTION -
          NEGOTIABLE INSTRUMENT ACT) NO. 50 of 2018
                              With
    CRIMINAL MISC.APPLICATION (FOR RECALL) NO. 2 of 2019
      In R/CRIMINAL REVISION APPLICATION NO. 50 of 2018
                              With
       R/CRIMINAL REVISION APPLICATION NO. 51 of 2018
                              With
    CRIMINAL MISC.APPLICATION (FOR RECALL) NO. 2 of 2019
      In R/CRIMINAL REVISION APPLICATION NO. 51 of 2018
==========================================================
                 VISHAL CHANDUBHAI UMRANIYA
                             Versus
                    STATE OF GUJARAT & ANR.
==========================================================
Appearance:
MR JIGNESH L HAJARE(3994) for the Applicant(s) No. 1
MR ALOK M THAKKAR(6510) for the Respondent(s) No. 2
MS SHRUTI PATHAK, APP for the Respondent(s) No. 1
MR SANJAY H PANDIT(7756) for the Respondent(s) No. 2
==========================================================
  CORAM:HONOURABLE MR. JUSTICE HASMUKH D. SUTHAR

                                            Date : 07/04/2026
                                             ORAL ORDER

          It is reported that applicant Vishal Chandubhai Umraniya
has expired on 23.05.2024 pending the present revision
applications. A copy of death certificate of the applicant is taken
on record.

          In view of above, present revision applications stand
disposed of as having abated. Rule is hereby discharged. Interim
relief if any stands vacated forthwith.



                                                                     (HASMUKH D. SUTHAR, J.)
Ajay
       Original copy of this order has been signed by the Hon'ble Judge.
       Digitally signed by: AJAY CHANDRAN MENON(HC00939), PRINCIPAL PRIVATE SECRETARY, at High Court of Gujarat on 07/04/2026 17:40:25



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