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    <title>2026 (1) TMI 434 - Supreme Court</title>
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    <description>Cognizance of offences under Sections 448 and 451 of the Companies Act, 2013 could not be taken on a private complaint because Section 448 is inextricably linked to the punishment for fraud under Section 447, and Section 212(6) requires a complaint by the SFIO Director, an authorised Central Government officer, or the statutory complainant. Section 451 was treated as derivative and could not stand independently in that setting, so the company-law prosecution was quashed to that extent. The IPC allegations, however, could not continue before the Special Court once the Companies Act offences fell away, and the complaint had to be transferred to the competent territorial court. Continuation of the IPC proceedings was not treated as abuse of process.</description>
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      <description>Cognizance of offences under Sections 448 and 451 of the Companies Act, 2013 could not be taken on a private complaint because Section 448 is inextricably linked to the punishment for fraud under Section 447, and Section 212(6) requires a complaint by the SFIO Director, an authorised Central Government officer, or the statutory complainant. Section 451 was treated as derivative and could not stand independently in that setting, so the company-law prosecution was quashed to that extent. The IPC allegations, however, could not continue before the Special Court once the Companies Act offences fell away, and the complaint had to be transferred to the competent territorial court. Continuation of the IPC proceedings was not treated as abuse of process.</description>
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