MUNNA LAL vs STATE OF UTTAR PRADESH

The Supreme Court held that Section 5A of the Prevention of Corruption Act, 1947 is mandatory, and an investigation not conducted by an authorized officer is illegal. However, such illegality does not vitiate the trial unless it results in a miscarriage of justice, which was not demonstrated in this case. The Court upheld the conviction under Section 5(2) read with Section 5(1)(c) of the Act, affirming the High Court's decision to reduce the sentence but set aside the fine imposed.