Amal Kumar Jha vs State Of Chhatisgarh & Anr

The Supreme Court held that under Section 197(1) Cr.P.C., sanction to prosecute is necessary when the act or omission of a public servant is in discharge of official duty. The Court found that the appellant's failure to provide a government vehicle for transferring a patient constituted an act in discharge of his official duty, thus requiring sanction for prosecution. The Court overturned the lower courts' decisions, ruling that the rejection of the appellant's application for discharge was incorrect, and the prosecution could not proceed without the necessary sanction.