Murari Lal Chhari vs Munishwar Singh Tomar

The Supreme Court held that the dismissal of a complaint under Section 203 of the CrPC was improper as the learned Magistrate failed to consider the necessity of sanction under Section 197 of the CrPC for prosecuting public servants. The Court emphasized that the requirement of sanction is mandatory when the alleged acts are committed in the discharge of official duties. The Court set aside the dismissal order and directed the Magistrate to reconsider the complaint in light of the proper legal standards.