ANIL KUMAR vs M.K AIYAPPA

The Supreme Court held that a Special Judge cannot refer a private complaint for investigation under Section 156(3) Cr.P.C. without a valid sanction order under Section 19 of the Prevention of Corruption Act, 1988. The Court emphasized that the requirement of sanction is a prerequisite for entertaining complaints against public servants for offenses committed in the discharge of their duties. Consequently, the Court upheld the High Court's decision to quash the Special Judge's order and the complaint, reinforcing the necessity of following procedural safeguards in corruption cases.