Inspector Of Police & Ors vs Battenapatla Venkata Ratnam & Anr

The Supreme Court held that sanction under Section 197 of the Code of Criminal Procedure, 1973 is not required to initiate criminal proceedings against public servants accused of offences such as Sections 420, 468, 477A, and 120B IPC when the alleged acts are not in discharge of their official duties. The Court clarified that actions like fabrication of records and misappropriation of funds, while committed in an official capacity, do not constitute acts performed in the discharge of official duties. Consequently, the High Court's order quashing the proceedings for lack of sanction was deemed illegal and unsustainable, leading to the reinstatement of the criminal proceedings.