The reference was made by Justice P N Prakash, who wanted the chief justice to constitute a full bench to decide several questions of law, including whether such appeals can be entertained by sessions courts under Section 372 of CrPC or by the high court under Section 378(4) and (5) of CrPC or whether there are concurrent remedies available with the right to the complainant to elect the forum of their choice.

The reference was made by Justice P N Prakash, who wanted the chief justice to constitute a full bench to decide several questions of law, including whether such appeals can be entertained by sessions courts under Section 372 of CrPC or by the high court under Section 378(4) and (5) of CrPC or whether there are concurrent remedies available with the right to the complainant to elect the forum of their choice.

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