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Issues: Whether the sanction accorded for prosecution was valid and disclosed due application of mind.
Analysis: The sanction order itself set out the relevant allegations, the period of check, the known sources of income, the expenditure, the assets acquired, and the resulting disproportionate assets. The sanctioning authority also entered the witness box and stated that he had considered the CBI report and discussed the matter with the legal department before granting sanction. In such circumstances, the sanction was not a mechanical approval, and the objection that the material was not properly placed before the authority could not be sustained. The defect found by the trial court was therefore erroneous.
Conclusion: The sanction was valid and there was due application of mind; the challenge to prosecution on that ground failed.
Ratio Decidendi: A sanction for prosecution is valid where the order itself discloses the material facts constituting the offence and the sanctioning authority's consideration of the record, or where extrinsic evidence shows that the relevant materials were placed before the authority and applied to mind.