S. N. BANERJEE vs BABU LAL GUPTA (DHANUKA) & ORS.

The Supreme Court held that the authorization required under Section 187A of the Sea Customs Act was obtained by the appellant prior to filing the complaint, thus satisfying the statutory requirement. The Court clarified that Section 196A of the Code of Criminal Procedure does not necessitate an application from a person holding specific authorization, allowing the Chief Presidency Magistrate to consent to proceedings based on an application from any individual. Consequently, the appeal was allowed, and the proceedings were deemed valid as both statutory requirements were fulfilled before the complaint was filed.