State Of Maharashtra vs Laljit Rajshi Shah & Ors

The Supreme Court addressed whether the Chairman of a Co-operative Society qualifies as a public servant under Section 21 of the Indian Penal Code for the purposes of the Prevention of Corruption Act, 1947. The Court held that the definition of 'public servant' in Section 21 IPC is not expanded by Section 161 of the Maharashtra Co-operative Societies Act, thus the accused cannot be prosecuted under the Prevention of Corruption Act without prior sanction. The appeals were dismissed, affirming the High Court's ruling that the accused were not public servants as defined by law.