DAULAT RAM vs STATE OF PUNJAB

The Supreme Court held that for a prosecution under Section 182 IPC, a written complaint by the concerned public servant, as mandated by Section 195 of the Code of Criminal Procedure, is essential for the court to take cognizance of the offence; otherwise, the trial is without jurisdiction ab initio. The Court clarified that the offence under Section 182 is complete upon the making of a false report, regardless of whether action is taken on it. The conviction of the appellant was set aside due to the lack of a proper complaint.