HAZARI LAL vs STATE OF BIHAR

The Supreme Court upheld the conviction of the appellant under Section 353 of the Indian Penal Code for using criminal force to deter a public servant from discharging his duty. The act of snatching account books from the Assistant Superintendent of Commercial Taxes constituted the use of force, as it caused a motion to the officer's hands within the meaning of Section 349 IPC. The Court clarified that the officer was lawfully entitled to inspect the books under the Bihar Sales Tax Act, and the prosecution under Section 353 was valid despite the potential applicability of Section 26(1)(h) of the Sales Tax Act, which required prior sanction for prosecution.