In Brief
The respondent's wife died under the medical care of three doctors. After unsuccessful complaints to the Medical Council and consumer forums, the Supreme Court eventually held the doctors civilly (not criminally) liable for negligence. The respondent then filed a criminal complaint against members of the Medical Council's Inquiry Committee, alleging they conspired to suppress expert evidence and save the doctors. The Supreme Court held that the complaint disclosed no criminal offence: suppressed expert opinions are not 'evidence of an offence' under Section 201 IPC, and departmental proceedings are not 'judicial proceedings' under criminal law. The criminal appeal was allowed and the complaint quashed.
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