INSPECTOR OF POLICE vs BATTENAPATLA VENKATA RATNAM

The Supreme Court addressed the necessity of sanction under Section 197 of the Code of Criminal Procedure, 1973, for initiating criminal proceedings against public servants accused of offences under Sections 420, 468, 477A, and 120B read with Section 109 of the Indian Penal Code. The Court held that the question of whether the accused acted in discharge of their official duties is crucial, and that the alleged offences of cheating and manipulation of records do not fall within the scope of their official duties. Consequently, the Court overturned the High Court's order quashing the proceedings due to lack of sanction, emphasizing that such sanction is not required in this context.