DR. BALIRAM WAMAN HIRAY vs JUSTICE B. LENTIN AND OTHERS

The Supreme Court held that a Commission of Inquiry constituted under the Commission of Inquiry Act, 1952 does not qualify as a 'Court' for the purposes of Section 195(1)(b) of the Code of Criminal Procedure, 1973. The Court emphasized that the Commission is a fact-finding body and lacks the judicial authority to be classified as a Court unless explicitly declared by the Act. Consequently, the prosecution for perjury under Section 193 IPC was not applicable, affirming the High Court's dismissal of the appellant's petition.