Court’s Analysis: Revision under Sections 397/401 CrPC is confined to saying that jurisdictional error, patent illegality and gross miscarriage of justice has happened. Referring to the case of Amit Kapoor v. Ramesh Chander, the court maintained that revision is not a forum where the evidence is reappreciated unless there are findings that are grossly erroneous. In case of Offences under sections 279/304A IPC, rashness and negligence needs to be proved. The vague and undefined statement that a vehicle was at “high speed” — without establishing a relationship to negligent conduct — is inadequate. The prosecution also did not exclude mechanical failure, such as a tyre blow-out, or demonstrate how speed on its own caused the accident. Quoting Ram Chander v. State and Moti Singh v. State of Maharashtra, the court said that mere speed does not prove that the driving was rash and the burden is on the prosecution to show the absence of reasonable doubt. Decision: The High Court accepted the revision and quashed the conviction and sentence since there was no evidence to show that the speed of the vehicle caused negligence and other causes of the accident were not excluded. The doctrine of res ipsa loquitur could not substitute for hard evidence.