VASANTI DUBEY vs STATE OF M.P.

The Supreme Court addressed the procedural authority of a Special Judge under the Prevention of Corruption Act, 1988, particularly regarding the acceptance of closure reports under Section 173 Cr.P.C. The Court held that a Special Judge can direct the police to submit a charge-sheet if he finds that the case should not be closed, despite the lack of sanction for prosecution. The judgment clarifies the limits of judicial intervention in the investigative process and affirms the need for proper legal sanction before proceeding with prosecution under the Act.