Emperor vs Raja Kushal Pal Singh on 14 April, 1931
Broadly speaking we are inclined to agree with the reasoning
of the Allahabad Full Bench in Kushal Pal Singh's case(2).
This in our opinion reflects the better view,. The purpose
and object of the Legislature in creating the bar against
cognizance of private complaints in regard to the offences
mentioned in s. 195(1)(b) and (c) is both to save the
accused person from vexatious or baseless prosecutions
inspired by feelings of vindictiveness on the part of the
private complainants to harass their opponents and also to
avoid confusion which is likely to arise on account of
conflicts between findings of the courts in which forged
documents are produced or false evidence is led and the
conclusions of the criminal courts dealing with the private
complaint. It is for this reason as suggested earlier, that
the Legislature has entrusted the court, whose proceedings
bad been the
(1) A. I. R. 1965 Guj. 70.