The question that arises for consideration in the present essay is whether a revisional Court is required under the law to issue a notice to a respondent in a revision preferred against an order dismissing the complaint either in defult of appearance of complainant or on merits at the pre-summoning stage i.e. where an accused has not been summoned in a complaint at the pre-summoning stage. The law is very well settled and no longer res integra that an accused who has not been summoned, has no right to participate in the proceedings before a Court at the pre-summoning stage. Such a person can merely watch the proceedings but cannot participate or interfere in the proceedings till he/she is summoned as an accused by a Court. The Supreme Court (S. K. Das, J. L. Kapur and M. Hidayatullah, JJ.) in Vadilal Panchal v. Dattatraya Dulaji Ghadigoankar and another1 observed that enquiry under Section 202 of the Code of Criminl Procedure Code, 18 ....