SHYAM LAL SHARMA, ETC. vs STATE OF MADHYA PRADESH

The Supreme Court held that while Section 165 of the Code of Criminal Procedure requires reasons for a search to be recorded, this does not grant individuals the right to obstruct the investigation through physical assault or wrongful confinement. The Court affirmed the High Court's decision to convict the appellants under Sections 353 and 342 of the Indian Penal Code, emphasizing that obstruction of a search is a defensive act, but compelling officials to act against their will constitutes an offense. The conviction was upheld despite the alleged irregularities in the search process.