State Of West Bengal vs Sadan K. Bormal & Anr

The Supreme Court held that the 3rd Special Court, Calcutta, lacked jurisdiction to try offences under the Prevention of Corruption Act, 1947 after the enactment of the Prevention of Corruption Act, 1988, which repealed the earlier Act. The Court emphasized that jurisdiction must be expressly conferred, and since the Special Court was not empowered under the new Act, it could not proceed with the trial of offences committed under the repealed Act. Consequently, the High Court's decision to quash the proceedings was upheld, affirming the principle that jurisdiction is determined by the law in force at the time of trial.