Om Prakash & Ors vs State Of Jharkhand & Anr

The Supreme Court addressed the challenge to the Jharkhand High Court's order under Section 482 of the Criminal Procedure Code, which quashed criminal proceedings against police personnel accused of a fake encounter resulting in the death of Munna Singh. The Court held that the allegations of murder under Section 302 IPC, along with conspiracy under Section 120-B IPC, warranted further investigation and could not be dismissed at the preliminary stage. The Court emphasized that the requirement for sanction under Section 197 of the Code does not apply when the accused acted outside the scope of their official duties, thus allowing the prosecution to proceed.