GOVIND MEHTA vs STATE OF BIHAR

The Supreme Court held that the provisions of Section 195(1)(b) and (c) of the Code of Criminal Procedure do not bar the prosecution of the appellant for forgery under Section 471 IPC, as he was not a 'party to any proceeding in any court' regarding the transfer applications. The Court clarified that the charge under Section 167 IPC was justified and that the complaint filed by the District Prosecutor was valid. Consequently, the appeal was dismissed, affirming the lower courts' decisions regarding the legality of the trial.