MANORAMA TIWARI vs SURENDRA NATH RAI

The Supreme Court addressed the applicability of Section 197 of the Code of Criminal Procedure, 1973, in the context of criminal negligence against medical professionals. The Court held that the prosecution against the appellants, Dr. Manorama Tiwari and Dr. Pradeep Pandey, for alleged negligence resulting in the death of a patient, was not maintainable without prior sanction under Section 197 Cr.P.C. The High Court's dismissal of the appellants' revision application was affirmed, thereby upholding the Magistrate's order rejecting the application for sanction.