Sunday, 16 June 2024

Bombay HC: Bar contained in S. 197, CrPC cannot be read into the provisions of a special legislation like SC/ST Atrocities Act

 The net result would be that when by virtue of explanation to Sub-Section 1 of Section 197 of the Code of Criminal Procedure, no previous sanction is required in respect of the offence punishable under Section 509 and when even no such sanction is required in respect of offence under the Atrocities Act, the perception of the Investigating Officer in treating the impugned decision as preventing him from filing any report and the stand of the State to that effect is grossly erroneous and unsustainable in law. When no previous sanction is required for carrying out investigation and filing a final report in respect of offence punishable under Section 509 of the Indian Penal Code and Section 3 of the Atrocities Act, the Investigating Officer is under statutory duty to submit a final report before the Special Court and the latter would not be debarred from taking cognizance thereof for want of sanction or because of the decision, not to accord the sanction. {Para 21}

24. In view of the above, we allow the writ petition partly as

under :

i. It is declared that no previous sanction as contemplated

under Section 197 would be necessary for carrying out

investigation and filing a final report in respect of offence

punishable under Section 509 of the Indian Penal Code and

Section 3 of the Atrocities Act.

IN THE HIGH COURT OF JUDICATURE AT BOMBAY

BENCH AT AURANGABAD

CRIMINAL WRIT PETITION NO.1401 OF 2021

Dr. Rekha w/o Gowardhan Gaikwad Vs  The State of Maharashtra

CORAM : MANGESH S. PATIL & SHAILESH P. BRAHME, JJ.

PRONOUNCED ON: 11.06.2024

JUDGMENT (MANGESH S. PATIL, J.) :

Heard. Rule. Rule is made returnable forthwith. Learned

APP and the learned advocates for the respective respondents waive

service. At the joint request of the parties, the matter is heard finally at the stage of admission.

2. Shorn of the verbiage, the circumstances leading to the filing

of this writ petition are to the effect that the petitioner has been serving

as a Medical Officer Class – I and on the date of petition was posted in

the office of Health and Family Welfare and Training Centre, Aurangabad.

Respondent No.9 is the superior officer, whereas, respondent No.7 was

her colleague and respondent No.8 was also serving in the same

establishment as an Administrative Officer and were allegedly aware that

she belonged to a scheduled caste ‘Mahar’. Respondent No.9 allegedly

subjected her to humiliation and also used to make overtures since

03.06.2016. She approached Vedant Nagar Police Station and lodged a

detailed complaint on 29.01.2019. Since initially it was not accepted she

had to approach the Commissioner of Police and thereafter her complaint was received and Crime No.40/2019 was registered for the offences

punishable under Section 506 and 509 read with Section 34 of the Indian

Penal Code and for the offence punishable under Section 3 of the

Scheduled Caste and Scheduled Tribe (Prevention of Atrocities) Act, 1989

(herein after the Atrocities Act) against respondents No.7 to 9.

3. Since the Investigating Officer was not filing any final report,

the petitioner filed Criminal Writ Petition No.402/2020 seeking a

direction for filing the report. Simultaneously, respondent Nos.7 to 9

filed separate applications under Section 482 of the Code of Criminal

Procedure seeking quashment of the crime.

4. It transpires that the Investigating Officer solicited sanction

to prosecute respondents No.7 to 9, in the light of Section 197 of the

Code of Criminal Procedure. It was pointed out to this Court that

pursuant to such requisition by the Investigating Officer, by

communication dated 17.02.2021, which is under challenge in this Writ

Petition, the Investigating Officer was informed by the Under Secretary in

the Public Health Department of the State that the competent authority

(Hon’ble Chief Minister) had refused to accord sanction for the time

being. In view of such supervening event in view of the stand of the

State and the Investigating Officer pointing out his inability to file a final

report/charge-sheet, by the common order dated 23.08.2021, the

criminal applications of respondents No.7 to 9 for quashment were

disposed of granting them liberty to again apply for quashment if the

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charge-sheet was filed, in case the decision refusing to accord sanction

was set aside. To this later stage, by recording the submission of the

learned Senior advocate for the petitioner in respect of Writ Petition

No.402/2020, informing that the petitioner was still to decide if to

challenge the order/decision refusing to accord a sanction, and by

observing that the petitioner could challenge that decision, even that writ

petition was disposed of.

5. The present petition has been preferred with following

prayers :

“B] To quash and set-aside the order/communication dated

17.02.2021 passed by the under secretary Government of

Maharashtra in complaint bearing No.2018/pra.kra.57(bhag-

1)/seva 4 a By issuing appropriate writ, order direction as the

case may be.

C] To hold and declare that sanctioned under section 197 of

Cr.P.C. is not necessary in crime no.40 of 2019 registered with

Vedant-nagar police station Aurangabad. By issuing

appropriate writ, order direction as the case may be.

D] To direct the investigation agency to complete investigation

and file final report under Section 173 of Cr.P.C. in crime

no.40 of 2019 registered with Vedant-nagar police station

Aurangabad. By issuing appropriate writ, order direction as

the case may be.

E] To hold and declare that decision taken by the authority

refusing permission to submit charge-sheet in court in crime

No.40/2019 registered with Vedant-nagar Police Station

Aurangabad is illegal and contrary to the provisions of law by

issuing appropriate writ, order direction as the case may be.

F] To direct the investigation agency to complete investigation

and file final report under Section 173 of the Cr.P.C. in crime

no.40 of 2019 registered with vedant-nagar police station

Aurangabad. Pending hearing and final disposal of this

criminal writ petition.”

6. There being repetition of prayers, it can easily be gathered

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that the petitioner is now putting up a challenge to the

decision/communication dated 17.02.2021 and as a consequence

soliciting a direction to the Investigating Officer to submit a chargesheet/

final report. In the process, she is also soliciting a declaration that

the sanction under Section 197 of the Code of Criminal Procedure is not

required at all.

7. During pendency of this petition, pursuant to the

observations of the Court recorded from time to time the prosecutor was

directed to take instructions in view of the fact that the impugned

communication merely stated that the sanction was being refused for the

time being, to ascertain if some final decision was to be taken. Pursuant

thereto, the learned APP tendered across the bar written communication

received by him dated 12.04.2024 from the Deputy Secretary of the

Public Health Department of the State together with the annexures

containing the office note, bearing signatures of the hierarchy of the

officers right up to the Secretary, as also of the learned Minister and the

decision taken by the Hon’ble Chief Minister under his signature

approving the office submission and refusing sanction to prosecute

respondents No.7 to 9 finally.

8. The learned Senior advocate Mr. Sapkal would vehemently

submit that in view of specific wording of Section 197 of the Code of

Criminal Procedure, a Magistrate cannot take cognizance of the offence

unless there is a sanction accorded by the competent authority as

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respondents No.7 to 9 are the public servants. He would further submit

that in view of explanation to Sub-Section 1 of Section 197, even it is

clear that no sanction shall be required for proceeding against a public

servant for the offences inter alia punishable under Section 509 of the

Indian Penal Code. He would further submit that since the offence was

registered even under the Atrocities Act, bar contained under Section 197

cannot be read into the provisions of that Act which is a special statute

and which does not contain any such rider or precursor for taking

cognizance of the offence committed under that Act by a Special Judge.

9. He would then submit that assuming that sanction was

required for taking cognizance of the offence punishable under Section

506 of the Indian Penal Code, there should not have been any

impediment for the Investigating Officer to undertake the investigation

and depending upon the material collected by him to file a final

report/charge-sheet excluding that section, may be to the extent of

Section 509 of the Indian Penal Code and for the offence punishable

under Section 3 of the Atrocities Act. The impugned decision/order

refusing to accord sanction would not completely prohibit the

Investigating Officer in carrying out the investigation and submitting a

final report for the offences which do not require any sanction to

prosecute the public servants.

10. Mr. Sapkal would then submit that in fact, when the law

requires the competent authority to grant or refuse the sanction, there

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should have been a speaking order. The impugned communication dated

17.02.2021 is devoid of any reasons for want of which the petitioner has

been deprived of an opportunity to objectively challenge that decision,

causing a serious prejudice to her. He would submit that the

communication placed on record by the learned APP dated 12.04.2024

(supra) is only an office note endorsed by hierarchy of officers, the

learned Minister and a one line decision by the competent authority

(Hon’ble Chief Minister) approving the office note and refusing sanction.

He would submit that there is no order. These office submissions

approved by Hon’ble Chief Minister cannot be taken as an order.

11. Mr. Sapkal would submit that in any case, when the law does

not require any previous sanction to prosecute a public servant for the

offence punishable under Section 509 of the Indian Penal Code and

Section 3 of the Atrocities Act, Hon’ble Chief Minister could have clarified

the decision by expressly mentioning so and in that case, the

Investigating Officer could have then proceeded to submit a final report

under Sections 169 or 173 of the Code of Criminal Procedure.

12. Mr. Sapkal would then take us through the specific

allegations contained in the FIR and even the office note to buttress his

submission that what has weighed with the competent authority, was the

fact that respondents No.7 to 9 were granted bail by the High Court and

the allegations levelled by the petitioner could not be substantiated in the

internal inquiry and in fact were found to be unsustainable and the

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allegations in the FIR are the same as were the allegations inquired into

by the internal committee. He would submit that these could not have

been valid reasons for refusing sanction. Besides, these are now being

supplemented by the subsequent communication dated 12.04.2024 which

could not have been done in the light of Mohinder Singh Gill and Anr. Vs.

Chief Election Commissioner, New Delhi and Ors.; (1978) 1 SCC 405. Mr.

Sapkal would, therefore, submit that the writ petition be allowed and the

Investigating Officer be directed to file a final report.

13. The learned Additional Public Prosecutor Mr. Nerlikar would

vehemently submit that the law merely speaks about previous sanction of

the competent authority to prosecute a public servant. It is an

administrative decision and the competent authority is not under any

obligation to pass a reasoned order in strict sense. It is a matter of

decision making process. When the office submissions are put before the

competent authority after those were endorsed by several other

responsible officers and even the learned Minister, the decision cannot be

said to have been taken without any material. It is a matter of decision

making process and no objection can be raised on the ground that it is

not in any particular format. The reasons can easily be gathered and the

petitioner is aware about it. He would, therefore, submit that since now

the sanction has been refused by the competent authority, no direction

can be given to the Investigating Officer to submit a final report.

14. Having heard both the sides and having perused the record,

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it is evident that there cannot be a dispute about the fact that the

competent authority (Hon’ble Chief Minister) by the impugned

communication had refused to accord sanction to prosecute respondents

No.7 to 9. Though it was initially being informed that the decision was

not final since a specific word ‘rwrkZl’ (for the time being) was used in the

impugned communication, as is observed herein above, during pendency

of this writ petition, the learned APP has received written communication

dated 12.04.2024 together with annexures which have been placed on

the record. It is abundantly clear that a detail office note was put up and

finally, the competent authority has refused to accord sanction to

prosecute. In spite of our specific query to Mr. Sapkal, as to if the

petitioner was not intending to challenge this final decision, he would

persist in submitting that there is no decision to be challenged inasmuch

as there is no speaking order.

15. It is trite that the sanction to prosecute as contemplated

under Section 197 of the Code of Criminal Procedure is an administrative

decision and not a quasi judicial one. The whole purpose and object of

providing for such a condition precedent for launching the prosecution

against a public servant, is to prevent unscrupulous complaint being

lodged against them which would demoralize them and would create

obstacles in their day to day functioning. It is like a filter. If the

competent authority objectively takes some decision either way, it would

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be purely an administrative decision and it cannot be expected that he

would pass the detail order as if he was discharging a judicial or quasi

judicial function. A reference can be made to the decisions in the matter

of Surjit Singh Vs. State of Punjab; 1979 SCC OnLine P&H 64 (Punjab

and Haryana High Court) and State of Assam Vs. Niranjan Ghosh;

MANU/GH/0071/1994.

16. When, as is observed herein above, the decision was taken

pursuant to the office note conveying the reasons and it was duly

approved by the competent authority, it cannot be said that the decision

suffers from any vice merely because no specific and separate order in a

particular format was passed by the competent authority (Hon’ble Chief

Minister). We, therefore, hold that the submission of Mr. Sapkal on this

count is not sustainable in law.

17. However, all such discussion regarding sustainability or

otherwise of the decision of the competent authority, in either granting or

refusing sanction proceeds on the premise that in fact, the law mandates

such previous sanction to be preceded before cognizance is taken by a

Magistrate or a Special Court.

18. As is evident from the explanation to sub-Section 1 of

Section 197, it contains list of certain offences where the legislature has

clearly explained that no previous sanction to prosecute a public servant

for these offences would be required. It contains inter alia offence

punishable under Section 509 of the Indian Penal code which is one of

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the offences registered pursuant to the FIR lodged by the petitioner.

19. Simultaneously, an offence has also been registered under

Section 3 of the Atrocities Act. A bar contained in Section 197 cannot be

read into the provisions of the Atrocities Act which does not contain any

such condition precedent. It is an offence under a special statute and

though the Special Judge would take cognizance, he would be doing so

pursuant to a specific provision contained in Section 14 of the Atrocities

Act and not under Section 190 of the Code of Criminal Procedure.

Besides, in view of the provision contained in Section 18-A of the

Atrocities Act, the Investigating Officer shall not require approval for

registration of an FIR and for arrest of the accused and cannot resort to a

procedure other than that is provided under the Act.

“18-A. No enquiry or approval required.—

(1) For the purposes of this Act,—

(a) preliminary enquiry shall not be required for registration of

a First Information Report against any person; or

(b) the investigating officer shall not require approval for the

arrest, if necessary, of any person,

against whom an accusation of having committed an offence

under this Act has been made and no procedure other than that

provided under this Act or the Code shall apply.

(2) The provisions of Section 438 of the Code shall not apply to

a case under this Act, notwithstanding any judgment or order or

direction of any Court.”

20. In this context, suffice for the purpose to refer to and rely

upon the decision of the Supreme Court in the matter of Union of India

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Vs. State of Maharashtra; (2020) 4 SCC 761. Relevant paragraphs read

as under :

“63. By the guidelines issued, the anomalous situation may crop

up in several cases. In case the appointing authority forms a

view that as there is no prima facie case the incumbent is not

to be arrested, several complications may arise. For the arrest

of an offender, may be a public servant, it is not the provision

of the general law of CrPC that permission of the appointing

authority is necessary. No such statutory protection is

provided to a public servant in the matter of arrest under IPC

and CrPC as such it would be discriminatory to impose such

rider in the cases under the 1989 Act. Only in the case of

discharge of official duties, some offence appears to have

been committed, in that case, sanction to prosecute may be

required and not otherwise. In case the act is outside the

purview of the official discharge of duty, no such sanction is

required.

64. The appointing authority cannot sit over an FIR in case of

cognizable, non-bailable offence and investigation made by

the police officer; this function cannot be conferred upon the

appointing authority as it is not envisaged either in CrPC or

the 1989 Act. Thus, this rider cannot be imposed in respect of

the cases under the 1989 Act, may be that provisions of the

Act are sometimes misused, exercise of power of approval of

arrest by the appointing authority is wholly impermissible,

impractical besides it encroaches upon the field reserved for

the legislature and is repugnant to the provisions of general

law as no such rider is envisaged under the general law.”

21. The net result would be that when by virtue of explanation to Sub-Section 1 of Section 197 of the Code of Criminal Procedure, no previous sanction is required in respect of the offence punishable under Section 509 and when even no such sanction is required in respect of offence under the Atrocities Act, the perception of the Investigating Officer in treating the impugned decision as preventing him from filing any report and the stand of the State to that effect is grossly erroneous and unsustainable in law. When no previous sanction is required for carrying out investigation and filing a final report in respect of offence punishable under Section 509 of the Indian Penal Code and Section 3 of the Atrocities Act, the Investigating Officer is under statutory duty to submit a final report before the Special Court and the latter would not be debarred from taking cognizance thereof for want of sanction or because of the decision, not to accord the sanction.

22. We would refer to and rely upon the decision of the Supreme

Court in the matter of A. Sreenivasa Reddy v. Rakesh Sharma, (2023) 8

SCC 711. Relevant paragraphs read as under :

“59. Thus, although in the present case, the appellant has been

discharged from the offences punishable under the PC Act, 1988

yet for IPC offences, he can be proceeded further in accordance

with law.

60. From the aforesaid, it can be said that there can be no thumb

rule that in a prosecution before the Court of Special Judge, the

previous sanction under Section 19 of the PC Act, 1988 would

invariably be the only prerequisite. If the offences on the charge

of which, the public servant is expected to be put on trial include

the offences other than those punishable under the PC Act, 1988

that is to say under the general law (i.e. IPC), the court is bound

to examine, at the time of cognizance and also, if necessary, at

subsequent stages (as the case progresses) as to whether there is

a necessity of sanction under Section 197 Cr.P.C.

61. There is a material difference between the statutory requirements

of Section 19 of the PC Act, 1988 on one hand, and Section 197

Cr.P.C., on the other. In the prosecution for the offences

exclusively under the PC Act, 1988, sanction is mandatory qua

the public servant. In cases under the general penal law against

the public servant, the necessity (or otherwise) of sanction under

Section 197 Cr.P.C. depends on the factual aspects. The test in the

latter case is of the “nexus” between the act of commission or

omission and the official duty of the public servant. To commit an

offence punishable under law can never be a part of the official

duty of a public servant. It is too simplistic an approach to adopt

and to reject the necessity of sanction under Section 197 Cr.P.C.

on such reasoning. The “safe and sure test”, is to ascertain if the

omission or neglect to commit the act complained of would have

made the public servant answerable for the charge of dereliction

of his official duty. He may have acted “in excess of his duty”, but

if there is a “reasonable connection” between the impugned act

and the performance of the official duty, the protective umbrella

of Section 197 Cr.P.C. cannot be denied, so long as the discharge

of official duty is not used as a cloak for illicit acts.”

23. In view of such state of affairs, in our considered view, the

impugned order though, cannot be said to be wholly erroneous or illegal,

it can only be treated as refusing to accord sanction wherever it is

required by law like for the offence punishable under Section 506.

Therefore, we do not find any flaw in the decision making process

leading to refusing to accord sanction and the reasons therefor

considered by the competent authority (Hon’ble Chief Minister).

24. In view of the above, we allow the writ petition partly as

under :

i. It is declared that no previous sanction as contemplated

under Section 197 would be necessary for carrying out

investigation and filing a final report in respect of offence

punishable under Section 509 of the Indian Penal Code and

Section 3 of the Atrocities Act.

ii. The Investigating Officer shall complete the investigation

and submit a final report except for the offence punishable

under Section 506.


iii. It would always be open for respondents No.7 to 9, in

accordance with the liberty granted by this Court (supra) to

apply for quashment of the charge-sheet by resorting to

Section 482 of the Code of Criminal Procedure.

iv. The investigation shall be concluded and final report shall

be filed as expeditiously as possible and in any case within

six weeks.

25. Rule is made absolute in above terms.

[ SHAILESH P. BRAHME ] [ MANGESH S. PATIL ]



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