Previous sanction for official-duty acts was required because the alleged conduct had a direct nexus with administrative processing.

Previous sanction under Section 197 CrPC was mandatory before prosecuting a public servant where the alleged acts had a reasonable and direct nexus with official duty. The Court applied the settled test that protection depends on whether the conduct complained of was connected with the discharge of official functions, and examined the respondent's role as limited to paperwork in the lease-processing file. As the allegations arose from that administrative process, cognisance could not be taken without prior sanction, and the respondent was entitled to the statutory protection.

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Issues: Whether previous sanction under Section 197 of the Code of Criminal Procedure, 1973 was required before prosecuting the public servant for acts allegedly done in connection with processing the lease and related papers.

Analysis: Section 197 protects a public servant from prosecution for offences alleged to have been committed while acting or purporting to act in the discharge of official duty, and the controlling test is whether the alleged act bears a reasonable and direct connection with the official function. The role attributed to the respondent was confined to paper work in the same administrative process in which other officers involved in the file had already been granted protection. The allegation of conspiracy and omission was examined in the context of that official processing, and the absence of sanction was therefore material because cognisance could not be taken without previous sanction if the act was connected with official duty.

Conclusion: Previous sanction under Section 197 was required, and the respondent was entitled to the protection of that provision.

Final Conclusion: The challenge to the High Court's order failed, and the proceedings could not continue against the respondent without the requisite sanction.

Ratio Decidendi: Where the alleged offence has a reasonable and direct nexus with the performance of official duties, previous sanction under Section 197 is mandatory before cognisance can be taken against the public servant.

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