Mahendra Lal Das vs State Of Bihar And Ors

The Supreme Court held that the delay in granting sanction for prosecution under Sections 5(1)(e) and 5(2) of the Prevention of Corruption Act, 1947, infringes the right to life and liberty under Article 21 of the Constitution of India. The Court emphasized that prolonged inaction by the investigating agency is unacceptable and can lead to quashing of FIRs if it violates fundamental rights. The appeal was allowed, quashing the FIR against the appellant due to the excessive delay in sanctioning prosecution.