M/S. PENNAR PATERSON LTD. vs M/S. SHIKSHAK SAHAKARI BANK LTD.

The Supreme Court held that the expression 'other legal proceedings' in Section 446(1) of the Companies Act, 1956 does not include criminal proceedings, affirming the High Court's decision which relied on M/s. BSI Ltd. & Anr. vs. Gift Holdings Pvt. Ltd. & Anr. Etc. [AIR 2000 SC 926]. The Court found no merit in the appellant's arguments and dismissed the appeal without costs, reinforcing the precedent established in the earlier case.