Which of the following is not a "public servant" within the meaning of Section 2(28) of the Bharatiya…

Under Section 2(28) of the Bharatiya Nyaya Sanhita, 2023 (formerly Section 21 of the Indian Penal Code, 1860), Judges, officers of a Court of Justice including a liquidator, receiver, or commissioner, and members of a panchayat assisting a Court of Justice are expressly included as public servants. As held by the Supreme Court in S.S. Dhanoa v. Municipal Corporation, Delhi (1981) and State of Maharashtra v. Laljit Rajshi Shah (2000), "A Secretary of a cooperative society" registered under a Cooperative Societies Act does not fall within the definition of a public servant under the general penal code.