Key legal question
Whether the appellant had standing to file a criminal appeal as an injured private complainant.
Extracted holding
He lacked standing because he was not directly injured by the offence and thus was neither an injured person nor a private complainant for Art. 81(1)(b)(5) BGG.
Extracted reasoning
The false-certification offence protected the integrity of documentary evidence, not the appellant's individual interests. His alleged harm stemmed from the dismissed property-related offences, not from the separate false-certification charge.