THE STATE OF UTTAR PRADESH vs BHAGWANT KISHORE JOSHI

The Supreme Court held that the first stage of investigation conducted by a Sub-Inspector without prior permission from the Magistrate under Section 5A of the Prevention of Corruption Act was an 'investigation' as defined under Section 4(1) of the Code of Criminal Procedure, 1898. However, the subsequent rectification by obtaining the necessary permission did not prejudice the accused, and thus the conviction under Section 5(2) of the Prevention of Corruption Act was upheld. The Court emphasized that irregularities in investigation do not automatically invalidate a conviction unless a direct nexus between the irregularity and the conviction is established.