Private complaint for false statements before Rent Controller remains maintainable; criminal proceedings were not quashed.

A private complaint alleging false statements before a Rent Controller was held maintainable because the Rent Controller is a statutory quasi-judicial authority, not a court in the conventional sense. Since it cannot invoke the jurisdiction under section 340 CrPC, the bar under section 195(1) CrPC applicable to court complaints did not operate in the same manner. On the facts, no basis was shown to interfere with the summoning order, and the criminal proceedings were not quashed.

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Issues: Whether a private complaint was maintainable for alleged false statements made before the Rent Controller and whether the criminal proceedings arising from such complaint were liable to be quashed.

Analysis: The Rent Controller, though discharging quasi-judicial functions, is a statutory authority and not a court in the conventional sense. As a creature of statute, it can act only within the powers expressly conferred upon it, and it cannot invoke the jurisdiction contemplated by section 340 of the Code of Criminal Procedure, 1973. In that situation, the bar applicable to complaints by a court under section 195(1) of the Code of Criminal Procedure, 1973 does not apply in the same manner, and a private complaint alleging false evidence before the Rent Controller remains maintainable. On the facts, no ground was made out to interfere with the summoning order or to quash the criminal proceedings.

Conclusion: The private complaint was maintainable and the prayer for quashing was rejected.

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