National Small Industries Corp.Ltd vs State (Nct Of Delhi) & Ors

The Supreme Court addressed whether a complaint for dishonor of a cheque filed by a government company, represented by a public servant, qualifies for exemption under clause (a) of the proviso to Section 200 of the Code of Criminal Procedure. The Court held that the representation by a public servant does not automatically confer the status of a public servant on the government company itself, thus the mandatory requirement of examining the complainant under Section 200 must be followed. The High Court's order quashing the summoning order was upheld, emphasizing the necessity of adhering to procedural requirements in criminal complaints.