In Brief
An Assistant Provident Fund Commissioner filed a complaint against an employee for obstructing proceedings under Section 7A of the Employees Provident Fund Act and abusing the presiding officer. A magistrate convicted the respondent; the Sessions Judge released him on probation; the High Court acquitted him, holding that Section 7A proceedings are not 'court' proceedings. The Supreme Court held that Section 7A proceedings, being statutorily invested with power to take evidence on oath, constitute 'judicial proceedings' and must be treated consistently under Section 228 IPC and Section 195(1)(b) CrPC. Complaints for obstruction must be filed directly before a magistrate, not before an appellate tribunal. The appeal was allowed and the High Court's order set aside.
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