Prosecution sanction upheld despite clerical corrigendum; prejudice claims should ordinarily be tested at trial, not used to quash proceedings.

The Supreme Court held that a prosecution sanction validly approved by the competent authority is not vitiated by minor clerical corrections in a later corrigendum. The Finance Minister had accorded approval after the matter moved through normal administrative channels, and the earlier file notings did not show any refusal of sanction or any extraneous influence. The corrigendum only corrected typographical matters, split the demand into two amounts, and removed some penal provisions, which was beneficial to the accused and did not alter the sanction's substratum. Allegations of prejudice were treated as factual matters ordinarily for trial, not for quashing at the threshold. The High Court's interference was therefore set aside and the prosecution was allowed to continue.

---

---

Issues: Whether the High Court was justified in interfering with the sanction order for prosecution on the grounds of alleged want of independent application of mind, alleged unauthorized corrigendum, and purported invalidity of the revised sanction.

Analysis: The sanctioning authority was the Finance Minister, and the original record showed that the matter was processed through the usual administrative levels before approval was accorded. The earlier file notings did not amount to a refusal of sanction, nor was there material to show any undue pressure or extraneous influence on the sanctioning authority. The corrigendum merely corrected typographical matters and split the alleged demand into two amounts, while also dispensing with some penal provisions, which was beneficial to the accused. It did not alter the substratum of the sanction already approved in the file. The validity of a sanction order, where one exists, is ordinarily tested on the question of prejudice to the accused, which is a factual matter to be examined at trial, not in proceedings under the writ or inherent jurisdiction.

Conclusion: The High Court was not justified in quashing the sanction order. The sanction was upheld and the prosecution was directed to proceed in accordance with law.

Final Conclusion: The challenge to the sanction failed, and the prosecution was allowed to continue, with trial to be completed expeditiously.

Ratio Decidendi: Where sanction for prosecution has been validly accorded by the competent authority, minor clerical corrections do not invalidate it, and challenges based on alleged prejudice should ordinarily be examined at trial rather than being entertained to quash the prosecution at the threshold.

---