Wrong Statement vs. False Statement: Supreme Court Quashes Perjury Proceedings for Typographical Errors in Pleadings

Case Snapshot

• Case Name: Prabhakar Yeshwant Masram and Another v. Sou Tula Namdeorao Jaipurkar and Another

• Citation: 2026 INSC 724

• Bench: Justice Ujjal Bhuyan and Justice Atul S. Chandurkar

• Date of Judgment: July 21, 2026

• Area of Law: Criminal Law, Contempt of Court, Perjury, Code of Criminal Procedure

Judgment in Brief

The Supreme Court allowed the appeal and quashed the orders directing the initiation of criminal proceedings against the appellants under Sections 193, 199, and 200 of the Indian Penal Code, 1860. The Court held that the lower court erred in directing the filing of a complaint merely on a prima facie finding that "wrong statements" had been made in the pleadings, without recording any satisfaction that "false statements" had been made or that it was expedient in the interest of justice to initiate proceedings. The Court clarified that a "wrong statement" is materially different from a "false statement." A false statement implies deliberate intention to deceive, whereas a wrong statement may be an inadvertent error or mistake. The typographical errors in the memorandum of appeal and stay application were bona fide and corrected before the Section 340 application was filed. The High Court also erred in improving the lower court's order in an appeal filed by the aggrieved party. The Court reaffirmed that proceedings under Section 340 of the CrPC should be initiated only in exceptional circumstances where deliberate falsehood on a matter of substance is established.

Relevant Facts

• The plaintiffs filed an application under Section 340 of the Code of Criminal Procedure, 1973, alleging that the defendant and his counsel had made false statements in the memorandum of appeal and the application for stay.

• The alleged errors were: using the word "dismissed" instead of "disposed of" in the memorandum of appeal, and omitting the word "no" in a sentence in the stay application.

• The defendant had already filed an application for correction of typographical errors on September 20, 2004, much before the Section 340 application was filed on April 27, 2005.

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