K.N.SHUKLA vs NAVNIT LAL MANILAL BHAT AND ANR.

The Supreme Court held that the appellant, a Class II railway officer officiating as a Class I officer, did not require sanction from the Central Government under Section 197 of the Code of Criminal Procedure for prosecution under Sections 166 and 167 of the IPC. The Court clarified that since the Railway Board is a separate entity from the Central Government, the appellant could be removed with the sanction of the Railway Board, thus not falling under the protection of Section 197. The appeal was allowed, and the necessity of sanction was negated.