The Supreme Court, however, held that Section 448, which concerns false statements, could not be read in isolation since the punishment prescribed for the offence is linked to Section 447, which deals with fraud.
It consequently held that an offence under Section 448 was an offence “covered under Section 447” for the purposes of Section 212(6). The statutory restriction on taking cognisance therefore applied, and cognisance could not be taken merely on the basis of a private complaint.