IQBAL SINGH NARANG & ORS. versus VEERAN NARANG

IQBAL SINGH NARANG & ORS. versus VEERAN NARANG

Though the Rent Controller discharges quasi-judicial functions, he is not a court for the purposes of Section 195(1) Cr.P.C. Therefore, a private complaint regarding false evidence is maintainable, and proceedings against the appellants cannot be quashed.

Parties
Appellant: Iqbal Singh Narang & Ors.; Respondent: Veeran Narang
Jurisdiction
India
Judgment Date
30 November 2011
Procedural Posture
Criminal Appeal / Final Judgment
Outcome
appeal dismissed
Legal Topics
False Evidence, Private Complaint, Powers of Rent Controller
Criminal Law Rent Control False Evidence Private Complaint Powers of Rent Controller

Case Brief

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Parties

Iqbal Singh Narang & Ors.

Appellant

Veeran Narang

Respondent

Procedural Posture

Criminal Appeal / Final Judgment

Legal Issues

  1. 1 Whether a private complaint is maintainable for allegedly false statements made before the Rent Controller under ss. 193/120-B IPC.
  2. 2 Whether the Rent Controller qualifies as a 'Court' under Section 195(1) Cr.P.C.

Ratio Decidendi

Though the Rent Controller discharges quasi-judicial functions, he is not a court for the purposes of Section 195(1) Cr.P.C. Therefore, a private complaint regarding false evidence is maintainable, and proceedings against the appellants cannot be quashed.

Court Disposition

appeal dismissed

Orders

  • Interim orders vacated.
  • Proceedings against the appellants to continue.