“This Court in Chajoo Ram, (1971) 1 SCC 774 held that the prosecution under Section 195 could be initiated only by the sanction of the Court and only if the same appears to be deliberate and conscious. The category of offences which fall under Section 195(1)(b)(i) refer to the offence of giving false evidence and offences against public justice which is distinctly different from those offences under Section 195(1)(b)(ii) where a dispute could arise whether the offence of forging a document was committed outside the Court or when it was in the custody of the Court. The case in hand squarely falls within the category of cases falling under Section 195(1)(b)(i) as the offence is punishable under Section 193. Therefore, the Magistrate has erred in taking cognizance of the offence based on a private complaint. This Court in M.S. Ahlawat, (2000) 1 SCC 278 has clearly held that private complaints are absolutely barred in relation to an offence said to have been committed under Section 193, IPC.”
– Hon’ble Justice S. Abdul Nazeer, Narendra Kumar Srivastava v. The State of Bihar, [Criminal Appeal No. 211 of 2019].