VISHAL AGRAWAL vs CHATTISGARH STATE ELECTRICITY BOARD &ANR

The Supreme Court addressed the applicability of the amended Section 151 of the Electricity Act, 2003, which allows courts to take cognizance of offences based on police reports under Section 173 of the Code of Criminal Procedure. The Court held that the amendment applies to pending complaints, thereby affirming the High Court's reversal of the Special Judge's order that had discharged the appellants due to a lack of authority in the complaint. The judgment clarified the interpretation of Section 151 and confirmed the Board's right to pursue action under the amended provisions.