Manju Surana vs Sunil Arora

The Supreme Court held that prior sanction under Section 19 of the Prevention of Corruption Act, 1988, read with Section 197 of the Code of Criminal Procedure, 1973, is mandatory before initiating any investigation against public servants for corruption allegations. The Court affirmed the lower court's decision to dismiss the complaint due to the absence of such sanction, referencing the precedent set in Anil Kumar v. M.K. Aiyappa. Consequently, the appeal was dismissed, upholding the requirement for sanction as a prerequisite for prosecution.