In Brief
This judgment addresses the jurisdiction of courts to take cognizance of false evidence and forgery allegations. The appellants had filed criminal complaints alleging the respondents committed false evidence under Sections 191-192 IPC in civil suits, later attempting to convert them into private complaints claiming forgery occurred. The Supreme Court held that Section 195(1)(b)(i) CrPC mandatorily bars private complaints for false evidence committed in or relating to court proceedings without court sanction. The ratio of Iqbal Singh Marwah applies only to Section 195(1)(b)(ii) forgery cases where documents are forged while in court custody (custodia legis), not to false evidence cases. The alleged debit notes did not qualify as false documents under Section 464 IPC. The Court reinstated the original complaints to proceed through the statutory Section 340 procedure rather than as private complaints.
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