Rizwan Ahmed Javed Shaikh & Ors vs Jammal Patel & Ors

The Supreme Court addressed the issue of maintainability of a complaint against police officers under Section 197(2) of the Cr.P.C. and the applicability of a government notification regarding police officers' protection. The Court held that the protection under the notification applies only to police officers acting in the maintenance of public order, and not merely in law and order situations. The Court overturned the High Court's dismissal of the appellants' petition, allowing the complaint to proceed against the police officers for wrongful confinement and assault under Sections 220 and 342 IPC and Sections 147 and 148 of the Bombay Police Act, 1951.