Raj Kishor Roy vs Kamleshwar Pandey & Anr

The Supreme Court held that the High Court erred in quashing the order of the Judicial Magistrate under Sections 323, 324, and 504 IPC, stating that the complaint against the police officer did not require sanction under Section 197 of the Code of Criminal Procedure. The Court clarified that if the alleged acts are not connected to the discharge of official duty, then no sanction is necessary. The judgment emphasized that the determination of whether an act is in discharge of duty must consider the reasonable connection between the act and the official duty, thereby allowing the appeal and reinstating the Magistrate's order.