MAHENDRA LAL DAS vs STATE OF BIHAR .

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, violated the appellant's right to life and liberty under Article 21 of the Constitution. The Court emphasized that undue delay in sanctioning prosecution can prejudice the accused's rights, and thus quashed the FIR against the appellant due to the inordinate delay of over 12 years without any action. The Court's ruling underscores the necessity for timely action in corruption cases to uphold constitutional rights.