NAR BAHADUR BHANDARI vs STATE OF SIKKIM .

The Supreme Court addressed the competence of the Special Judge (P.C. Act) Sikkim to try cases under Section 5(2) read with Section 5(1)(e) of the Prevention of Corruption Act, 1947, and corresponding provisions of the 1988 Act. The Court held that the withdrawal of consent by the State of Sikkim under Section 6 of the Delhi Special Police Establishment Act, 1946, was prospective and did not affect pending investigations. The Court reaffirmed that the C.B.I. could submit its report based on investigations conducted prior to the withdrawal, thereby upholding the jurisdiction of the Special Judge to proceed with the cases.