DELHI ADMINISTRATION vs CHANAN SHAH

The Supreme Court held that the provisions of sub-rules (1) and (2) of Rule 38 of the Punjab Police Rules, 1934, must be followed when a complaint against a police officer indicates a criminal offence in connection with official duties. The Court found that the inquiry against the respondent was vitiated as the necessary sanction from the District Magistrate was not obtained prior to the departmental inquiry, thus rendering the dismissal order invalid. The Court upheld the Division Bench's decision to quash the dismissal order due to non-compliance with procedural requirements under the Punjab Police Rules.