P.D. LAKHANI vs STATE OF PUNJAB .

The Supreme Court addressed the applicability of Section 195(1) of the Code of Criminal Procedure, 1973, in the context of a complaint regarding trademark infringement and copyright violation. The Court held that a complaint under Section 63 of the Copyright Act and Sections 78-79 of the Trade and Merchandise Marks Act, 1958, requires prior sanction for prosecution, emphasizing that the absence of such sanction renders the complaint invalid. Consequently, the appeal was dismissed, affirming the High Court's decision that the complaint was not maintainable without the requisite sanction.