MUKUL DALAL ETC. ETC. vs UNION OF INDIA & ORS. ETC. ETC.

The Supreme Court held that the appointment of a Special Public Prosecutor should not be made solely at the request of a private complainant, as it could lead to a travesty of justice. The Court emphasized that the Remembrancer of Legal Affairs must scrutinize requests for such appointments based on prescribed guidelines, ensuring that the primacy of the Public Prosecutor is maintained under the Code. The Court found Rule 22 of the Maharashtra Rules to be invalid and directed the State Government to modify it accordingly, while also stating that remuneration for the Special Public Prosecutor should generally come from State funds, with exceptions only in special cases.