KAMLA PRASAD SINGH vs HARI NATH SINGH & ANR.

The Supreme Court held that Section 218 IPC allows for private complaints against public servants for preparing false records, distinguishing it from Section 192 IPC, which pertains to false evidence intended for judicial proceedings. The Court ruled that while the bar under Section 195 CrPC applies to cases under Section 192 IPC, it does not apply to offences under Section 218 IPC, allowing the appellant's complaints against the Lekhpals to proceed. The Court clarified that the offence under Section 218 IPC is complete upon the preparation of the false record, irrespective of its use in judicial proceedings.