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State of Madhya Pradesh v. Ram Manohar Pandey

Criminal Appeal · 2014 INSC 902Decided 9 Dec 2014
Criminal Appeal Nos. 2547-2548 of 2014
Justice Sudhansu Jyoti Mukhopadhaya · Justice Prafulla C. Pant

Background

An engineer faced corruption allegations relating to municipal works, but prosecution sanction was refused while he was still serving. A court discharged him for want of sanction, and that order became final. After his retirement, the prosecution filed fresh charge sheets, eventually prompting the High Court to stop the renewed proceedings.

Decision Breakdown

The Supreme Court dismissed the State's appeals and left the High Court's relief intact. The competent authorities had refused sanction during service, and the earlier discharge had not been challenged. Retirement did not permit the State to defeat those decisions simply by filing another charge sheet. Applying the precedents and statutory position before it in 2014, the Court distinguished this situation from a refusal made only after retirement, when the sanction exercise would have served no purpose under the provision then considered.

Lesson Learnt

A prosecution cannot simply wait for retirement to bypass a competent refusal of sanction during service and an unchallenged discharge. This ruling concerns those particular circumstances and the legal provisions applied in 2014.

Official source (sci.gov.in)View Judgment (PDF)

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