BAKHSHISH SINGH DHALIWAL vs THE STATE OF PUNJAB

The Supreme Court upheld the conviction of the appellant under Section 420 IPC for submitting false bills to the Evacuee Government of Burma, affirming that each bill constituted a separate representation. The Court ruled that the joint trial with a government officer was valid despite the lack of sanction under Section 197 CrPC, as the officer's actions were not within the scope of public duty. The Court distinguished the case from Mita Prasad v. Emperor, clarifying that the timing of property transfer does not preclude charges under Section 420 IPC.