In Brief
Amit Vashistha (an Assistant Provident Fund Commissioner) filed a complaint under Section 228 IPC against Suresh for obstructing and assaulting him during adjudication proceedings under Section 7A of the Employees Provident Funds Act. The High Court acquitted Suresh, holding that Section 7A proceedings were not 'court' proceedings and thus the complaint was unmaintainable. The Supreme Court allowed the appeal, holding that Section 7A proceedings, being statutorily deemed 'judicial proceedings' with power to take evidence on oath, must be equated with 'courts' for purposes of Section 195(1)(b) CrPC. The complaint was therefore maintainable.
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