Companies Act false statements and material omissions can trigger Section 447 liability, supporting denial of regular bail in an economic offence case.

Allegations of false statements and material omissions under the Companies Act were treated as attracting Section 448, which deems a person liable under Section 447 where a required document contains a false statement or omits a material fact. The petitioner's claim of being a dummy director was not supported by the record; participation in company affairs and signature on financial statements were relied on instead. The complaint and investigation were viewed as disclosing serious economic misconduct involving inflated figures and diversion of funds across multiple companies, and the stricter approach to bail in economic offences was applied. Regular bail was therefore rejected, and parity with co-accused was not accepted.

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Issues: Whether the petitioner was entitled to regular bail in a complaint alleging false statements and material omissions under the Companies Act, and whether the offence under Section 448 of the Companies Act, 2013 attracted the rigours of punishment under Section 447 so as to justify denial of bail.

Analysis: The allegation was that the petitioner actively participated in the affairs of the companies and signed financial statements, and the plea of being a dummy director was found unsupported by the record. Section 448 of the Companies Act, 2013 specifically provides that where a person makes a false statement or omits a material fact in any document required under the Act, he becomes liable under Section 447. The complaint and the investigation were treated as revealing serious economic misconduct involving false statements, inflated figures, and diversion of funds across multiple companies. The Court also treated the Supreme Court's approach to stringent bail conditions in economic offences as applicable, and declined to accept parity with co-accused as a ground for bail.

Conclusion: The petitioner was not entitled to bail and the request for regular bail was rejected.

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