FATMA BIBI AHMED PATEL vs STATE OF GUJARAT

The Supreme Court interpreted Section 4 of the Indian Penal Code and Section 188 of the Code of Criminal Procedure, holding that the order taking cognizance against the appellant, a citizen of Mauritius, was invalid as the entire cause of action arose in Kuwait and lacked the necessary sanction under Section 188. The Court emphasized that the provisions of the IPC apply to Indian citizens committing offenses outside India, but the jurisdiction must be properly established. The appeal was allowed, overturning the High Court's decision.