Official-duty nexus under Section 197 CrPC determines sanction; disputed factual connection may be left for trial.

Previous sanction under Section 197 CrPC is required only where the alleged act bears a reasonable and inseparable connection with official duty; acts that merely use official position as an occasion, including corrupt conduct such as bribery, ordinarily fall outside that protection. Where the accused claims that the impugned conduct was integrally connected with official functions but that connection is disputed on the evidence, the issue may be deferred for trial rather than decided summarily. On that basis, no relief was granted at the present stage and the sanction question was left open for determination on the facts if necessary.

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Issues: Whether prosecution of a public servant for alleged conspiracy and corruption-related offences required previous sanction under Section 197 of the Code of Criminal Procedure, 1973, and whether relief could be granted at the stage when the factual basis of the claim of official-duty connection was still disputed.

Analysis: Section 197 imposes a statutory bar on cognizance where the act complained of is alleged to have been committed by a public servant while acting or purporting to act in the discharge of official duty. The governing test is whether there is a reasonable connection between the act and the official duty, so that the act can fairly be said to have been done in the course of performance of that duty, even if it exceeded what was strictly necessary. The protection does not extend to acts which merely use official position as an occasion or opportunity, and offences such as bribery or similar corrupt acts ordinarily fall outside the scope of official duty. However, where the accused asserts that the impugned acts were integrally connected with official functions and the truth of that claim depends on evidence, the question may have to be left open for decision at trial.

Conclusion: The Court held that no relief could be granted at the present stage because the asserted connection between the impugned acts and official duty required factual examination at trial, and the question of sanction was left to be decided in the main judgment if necessary.

Final Conclusion: The appeal failed and the prosecution was not quashed at this stage, leaving the sanction issue open for reconsideration on the evidence during trial.

Ratio Decidendi: Previous sanction under Section 197 is required only when the complained-of act bears a reasonable and inseparable connection with official duty; where that connection is disputed and requires evidence, the issue may be deferred to trial rather than decided summarily.

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