N.K.OGLE vs SANWALDAS @ SANWALMAL AHUJA

The Supreme Court held that the Tehsildar's actions of seizing the scooter and issuing a Demand Letter were in the discharge of his official duties, thus requiring prior sanction under Section 197 of the Code of Criminal Procedure for prosecution. The Court overturned the High Court's decision, which had found that the Tehsildar misused his powers, and reinstated the Sessions Judge's ruling that the complaint was not maintainable without such sanction. The judgment clarified the scope of immunity provided under Section 197 Cr.P.C. for public servants acting in their official capacity.