BABITA LILA vs UNION OF INDIA

The Supreme Court held that the Deputy Director of Income Tax (Investigation)-I, Bhopal lacked the competence to file a complaint under Sections 109, 191, 193, 196, 200, 420, 120B, and 34 IPC, as per Section 195(4) of the Code of Criminal Procedure. The Court found that the complaint was improperly filed since the alleged offences did not occur within the jurisdiction of the Chief Judicial Magistrate, Bhopal. Consequently, the Court quashed the proceedings initiated against the appellants, thereby upholding their challenge to the prosecution.