RAMESHWAR BHARTIA vs THE STATE OF ASSAM

The Supreme Court addressed the interpretation of 'personally interested' under Section 556 of the Criminal Procedure Code, determining that merely granting sanction for prosecution does not disqualify an officer from trying the case. The Court held that the trial and conviction of Rameshwar Bhartia by the same officer who sanctioned the prosecution were legal, as the officer's role in sanctioning did not equate to personal interest in the case. The judgment clarified the distinction between sanction and direction to prosecute, emphasizing that sanction is a permission based on a prima facie case, while direction involves a command that the prosecution must proceed.