MANJU SURANA vs RATAN SINGH

The Supreme Court addressed the necessity of prior sanction for prosecution of public servants under Section 19 of the Prevention of Corruption Act, 1988, in conjunction with Section 197 of the Code of Criminal Procedure, 1973. The Court held that without such sanction, no investigation could be initiated under Section 156(3) of the Cr.P.C. The appeal was dismissed, affirming the lower court's decision to close the complaint due to the absence of requisite sanction.