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Manish Kandpal vs. Sangeeta Pokhriyal

43. The parameters of the eighth exception were explained by the Hon'ble Supreme Court of India in the case of Subramanian Swamy v. Union of India, (2016) 7 SCC 221:

"...188. Again in M.C. Verghese v. T.J. Poonan, (1969) 1 SCC 37, it has been ruled that a person making libellous statements in his complaint filed in court is not absolutely protected in a criminal proceeding for defamation, for under the Eighth Exception and the illustration to Section 499 the statements are privileged only when they are made in good faith. . .