In Brief
A complainant filed a criminal case against members of a Medical Council's Inquiry Committee, alleging they had suppressed expert reports showing medical negligence and had conspired to exonerate the doctors. The Supreme Court held that disciplinary proceedings of the Medical Council are not 'judicial proceedings' as they do not involve oath-based evidence. Therefore, suppressing reports in such proceedings cannot constitute the offence of 'causing disappearance of evidence' under Section 201 IPC, nor can it amount to criminal conspiracy under Section 120B IPC since such conspiracy would not target an offence punishable with the required term of imprisonment. The Court allowed the appeal and quashed the complaint.
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