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Issues:
1. Whether the offenses punishable under sections 193 and 196 of the Indian Penal Code fall within the purview of section 195(1)(b)(i) of the Criminal Procedure Code. 2. Whether the Income-tax Officer can be considered as one of the "courts" under section 195 of the Criminal Procedure Code. Analysis: The petitioner was facing prosecution for offenses under sections 193, 196, and 420 of the Indian Penal Code, along with sections 276C and 277 of the Income-tax Act based on a complaint by the Income-tax Officer. The petitioner sought to quash the prosecution, arguing that offenses under sections 193 and 196 require compliance with section 195(1)(b)(i) of the Criminal Procedure Code, which mandates a written complaint by the court. The petitioner contended that the Income-tax Officer did not follow the procedure under section 340 of the Criminal Procedure Code, which was necessary to include these offenses in the prosecution. The court examined the provisions of sections 340 and 195 of the Criminal Procedure Code to determine whether the Income-tax Officer could be considered a "court" for the purpose of section 195. Referring to the Supreme Court's decision in Balwant Singh v. L. C Bharupal, the court held that the Income-tax Officer cannot be categorized as a revenue court under section 195. The Supreme Court's ruling established that the Income-tax Officer does not fall within the scope of sections 195 and 340 of the Criminal Procedure Code, thereby not requiring adherence to the procedures outlined in those sections before initiating prosecution for offenses under sections 193 and 196 of the Indian Penal Code. The court relied on the precedent set by the Supreme Court in Lalji Haridas v. State of Maharashtra while reaffirming the decision in Balwant Singh's case. Consequently, the court dismissed the petitioner's plea to quash the prosecution, concluding that the Income-tax Officer does not qualify as one of the courts specified in sections 195 and 340 of the Criminal Procedure Code, thereby upholding the validity of the ongoing prosecution against the petitioner.
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