Central Bureau Of Investigation vs M. Sivamani

The Supreme Court upheld the High Court's decision to quash the proceedings against the respondent under Section 182 IPC, emphasizing that cognizance for such offences can only be taken on a written complaint from the concerned public servant as mandated by Section 195(1)(a)(i) CrPC. The Court reiterated that the CBI's charge sheet did not constitute a valid complaint, thus rendering the proceedings invalid. The ruling clarified the necessity of adhering to procedural requirements in criminal conspiracy cases under Section 120-B IPC and related provisions.