STATE OF M.P vs RAM MANOHAR PANDEY

The Supreme Court held that under Section 13(1)(d) read with Section 13(2) of the Prevention of Corruption Act, 1988, prior sanction is necessary for prosecuting a public servant. The Court affirmed the High Court's decision to quash the charge-sheet against the respondent, Ram Manohar Pandey, due to the absence of valid sanction for prosecution, which was a prerequisite for taking cognizance of the offense. The Court emphasized that the order of discharge by the Special Judge had attained finality as it was not challenged by the State.