IQBAL SINGH NARANG vs VEERAN NARANG

The Supreme Court addressed the maintainability of private complaints under Sections 193, 420, and 120-B IPC in the context of proceedings before a Rent Controller. The Court held that the Rent Controller does not qualify as a 'Court' under Section 195(1) of the Code of Criminal Procedure, 1973, thus allowing for private complaints regarding false evidence. The High Court's dismissal of the Appellants' quashing petition was upheld, affirming that allegations of false statements made in rent proceedings can be pursued privately.