S.S. DHANOA vs MUNICIPAL CORPORATION, DELHI & ORS.

The Supreme Court held that the appellant, a member of the Indian Administrative Service loaned to a Cooperative Society, did not qualify as a public servant under clause Twelfth of Section 21 IPC. The Court ruled that he was neither in the service or pay of the Government nor employed in connection with the affairs of the Union, as required for prosecution under Section 197 Cr. P.C. The appeal was dismissed, affirming the lower courts' decisions that a cooperative society does not constitute a corporation as defined by the IPC.