Under Section 2(28) of the Bharatiya Nyaya Sanhita, 2023, which of the following is not a "public…

In R.S. Nayak v. A.R. Antulay, (1984) 2 SCC 183, a five-judge Constitution Bench of the Supreme Court held that a Member of the Legislative Assembly (M.L.A.) is not a "public servant" within the meaning of the penal code definition now contained in Section 2(28) of the Bharatiya Nyaya Sanhita, 2023 (formerly Section 21 of the Indian Penal Code, 1860), as an M.L.A. is not in the service or pay of the Government. By contrast, a Municipal Commissioner is expressly declared to be a public servant in the statutory Illustration to Section 2(28)(k), a liquidator is a public servant under Section 2(28)(c), and an arbitrator to whom any cause or matter has been referred by a Court is a public servant under Section 2(28)(e).