ELECTRICAL MANUFACTURING CO. LTD. vs D. D. BHARGAVA

The Supreme Court held that under Section 6 of the Imports & Exports (Control) Act, 1947, a complaint must be filed in writing by an authorized officer, and there is no requirement for the officer to apply his mind to the relevant materials before filing the complaint. The Court ruled that the principles applicable to cases requiring sanction for prosecution do not apply here, affirming that the complaint was valid as it was made by an authorized officer. Consequently, the Magistrate was correct in taking cognizance of the offence under Section 5 of the Act.