Anil Kumar & Ors vs M.K Aiyappa & Anr

The Supreme Court addressed the issue of whether a Special Judge can refer a private complaint under Section 200 Cr.P.C. for investigation without a valid sanction order under Section 19 of the Prevention of Corruption Act, 1988. The Court held that a complaint against a public servant must be accompanied by a sanction order, regardless of the stage of proceedings, affirming the High Court's decision to quash the Special Judge's order. This ruling emphasizes the necessity of obtaining governmental sanction prior to initiating proceedings against public servants under the Prevention of Corruption Act.