B.S. Goraya vs U.T. Of Chandigarh

The Supreme Court upheld the dismissal of the appellant's revision petition challenging the framing of charges under Section 13(2) read with Section 13(1)(e) of the Prevention of Corruption Act, 1988. The Court ruled that since the appellant was not in government service at the time the charge sheet was filed, the requirement for prior sanction under Section 19 of the Act was not applicable. The Court distinguished the facts from the precedent in State of U.P. v. Mohammad Nooh, asserting that the appellant's reinstatement did not retroactively confer the protections of a public servant at the time of the alleged offenses.