MANOHAR NATH KAUL vs STATE OF JAMMU & KASHMIR

The Supreme Court held that Section 197(1) of the Criminal Procedure Code mandates prior sanction for prosecuting a public servant only if the alleged offence is committed while acting in the discharge of official duties. In this case, the appellant, a Regional Officer, was accused of cheating under Section 420 IPC for including unauthorized expenses in T.A. bills. The Court ruled that the acts of cheating were not integrally connected to his official duties, thus no sanction was required, and the appeal was dismissed.