Disproportionate-assets prosecutions: no pre-FIR hearing required, and sanction is not vitiated by lack of elaborate reasons.

In a disproportionate-assets prosecution, the Court held that the accused has no right to a pre-FIR hearing before registration of the case, because the obligation to satisfactorily account for assets arises at trial. It also held that the sanction was not invalid merely because it did not contain elaborate reasons, where the accompanying material showed prima facie application of mind. Allegations of mala fides, by themselves, did not justify quashing when the prosecution was supported by specific factual averments and collected material. The power to quash criminal proceedings was said to be exceptional and to be used sparingly.

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Issues: Whether the High Court was justified in quashing the corruption prosecution on the grounds of absence of prior opportunity before registration of the case, alleged infirmity in sanction, and mala fides.

Analysis: The allegations concerned possession of assets disproportionate to known sources of income under the corruption law. The Court held that the requirement to satisfactorily account for such assets operates at the trial stage and does not entitle the public servant to a hearing before an FIR is registered. It further held that the sanction order and accompanying material disclosed prima facie application of mind and that the absence of elaborate reasons or a separate recital in the body of the sanction order did not invalidate it. On mala fides, the Court held that such allegations do not, by themselves, justify quashing where the prosecution is founded on specific factual averments and collected material. The Court also reiterated that the power to quash criminal proceedings after they have been launched must be exercised sparingly and only in exceptional cases.

Conclusion: The High Court was not justified in quashing the prosecution, and the challenge to the sanction and the plea of denial of natural justice failed.

Final Conclusion: The criminal proceedings were restored to continue in accordance with law, and the appeals succeeded.

Ratio Decidendi: In a prosecution for possession of disproportionate assets, no pre-FIR hearing is required before registration of the case or grant of sanction, and criminal proceedings should not be quashed on mere allegations of mala fides or supposed irregularity in sanction when the material discloses a prima facie case and the accused can explain the assets at trial.

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