RIZWAN AHMED JAVED SHAIKH vs JAMMAL PATEL .

The Supreme Court addressed the issue of maintainability of a complaint against police officers under Sections 220 and 342 IPC and Sections 147 and 148 of the Bombay Police Act, 1951, in light of Section 197(2) Cr.P.C. The Court held that the requirement for sanction under Section 197(2) is applicable to police officers acting in the discharge of their official duties, and since the appellants failed to obtain the necessary sanction, the complaint was rightly dismissed. The appeal was consequently dismissed, affirming the lower court's decision.