P.K.PRADHAN vs STATE OF SIKKIM REP. BY C.B.I.

The Supreme Court upheld the Sikkim High Court's decision that no sanction under Section 197 of the Code of Criminal Procedure, 1974, was required for the prosecution of the appellant, the former Secretary of the Rural Development Department, in a corruption case involving the then Chief Minister of Sikkim. The Court clarified that the prosecution under Sections 120-B IPC and the Prevention of Corruption Act, 1947 and 1988 was valid despite the absence of sanction, as the actions were not performed in the discharge of official duties. The appeal was dismissed, affirming the lower court's ruling.