Section 197 sanction not needed where alleged police coercion and intimidation were outside official investigative duty.

Section 197 CrPC protects a public servant only where the complained-of act is reasonably connected with official duty or its purported discharge. It does not cover misuse of authority, excess of power, or criminal conduct outside official functions. Allegations that a police officer threatened the complainant and her husband to withdraw a complaint and obtained signatures under coercion were treated as acts unrelated to investigative duty. Previous sanction was therefore not required, and the complaint and criminal process could not be quashed on that ground.

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Issues: Whether previous sanction under Section 197 of the Code of Criminal Procedure, 1973 was necessary for prosecuting a police officer for alleged extortion and criminal intimidation committed during investigation.

Analysis: Section 197 protects a public servant only when the act complained of is reasonably connected with the discharge or purported discharge of official duty. The protection does not extend to acts that amount to misuse or excess of authority, or to criminal conduct that is not part of the official functions of the officer. Allegations of threatening the complainant or her husband to withdraw a complaint and of obtaining signatures under coercion were not acts that could be treated as duties of an investigating officer.

Conclusion: Previous sanction was not required, and the complaint and process could not be quashed on the basis of Section 197.

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