RAKESH KUMAR MISHRA vs STATE OF BIHAR .

The Supreme Court held that the dismissal of the appellant's petition under Section 482 of the Code of Criminal Procedure, 1973, by the Patna High Court was justified as the requirement of sanction under Section 197 of the Code was not applicable in this case. The Court clarified that the provisions of Section 100(4) were not followed during the search, thus negating the need for sanction. The Court upheld the order of cognizance taken by the Judicial Magistrate for offences under Sections 342, 389, 469, 471, and 120B of the IPC, affirming the High Court's decision.