Tuesday 17 September 2024

Bombay HC: Officers Appointed To Assess Electricity Theft Are 'Public Servants', Court Can't Issue Process Against Them Without Sanction U/S 197 CrPC

 Section 169 of the Electricity Act, 2003 which defines the term public servants in pursuance to Section 21 of the Indian Penal Code includes the servants or the employees under Section 126 of the Electricity Act, 2003. As discussed above, the Board has authorized various officers including the Junior Engineers and linemen to detect the theft. Hence, they are covered under the definition of public servants in Section 169 of the Electricity Act, 2003. Therefore, the Court is of the view that the learned Judicial Magistrate First Class erred in issuing the process against the petitioners without sanction as required under Section 197 of the Criminal Procedure Code. This issue was not dealt with at all. The impugned order also does not reflect the application of mind. Hence, the petition deserves to be allowed. {Para 22}

IN THE HIGH COURT OF JUDICATURE AT BOMBAY

BENCH AT AURANGABAD

CRIMINAL WRIT PETITION NO. 744 OF 2008

 Syed Naeemuddin S/o Syed Khaja, Vs The State of Maharashtra.

 CORAM : S.G. MEHARE, J.

PRONOUNCED ON : SEPTEMBER 12, 2024.


1. The petitioners/employees of the then MSEDCL had

impugned the order of the learned Judicial Magistrate First Class


issuing process against them for the offences punishable under

Sections 323 and 506 of the Indian Penal Code in Criminal Case

No.114 of 2008 dated 17.06.2008 and the order of the learned

Additional Sessions Judge, Biloli passed in Criminal Revision No.17 of

2008 dated 08.09.2008 dismissing the revision.

2. The learned counsel for the petitioners submits that before

the complaint was filed against the petitioners, an FIR was registered

against the complainant for the offences punishable under Sections

353 and 504 of the Indian Penal Code and Section 135 of the Indian

Electricity Act, 2003. However to counter that case, respondent no.2

had filed the false complaint against them. He submitted that the

petitioners being public servants, the order issuing the process against

them could not be passed unless the sanction is obtained as provided

under Section 197 of the Criminal Procedure Code. No Court can take

the cognizance against the public servants, who are the public

servants defined under Section 21 of the Indian Penal Code or any

other relevant provisions of law. To bolster his argument, he relied on

the case of Lalankumar Singh and Others Vs. State of Maharashtra,

2022 SCC Online SC 1383 and State of Haryana and Others Vs.

Bhajanlal and Others, 1992 Supp(1) SCC 335. He also submitted the

notification of the State of Maharashtra dated 04.06.2005 to bolster

his argument that the entire property of the Maharashtra State


Electricity Board with assets and liability has been vested with the

State Government.

3. The learned counsel for the respondent submits that the

petitioners were not the public servants at the relevant time. They

were the employees of a Board run by the Government. Therefore,

sanction under Section 197 of the Criminal Procedure Code was not

essential. The Court had directed an inquiry under Section 202 of the

Criminal Procedure Code. After receiving the report, the learned

Magistrate has applied his mind and satisfied that there was a case for

issuing process against the petitioner. The case laws relied upon by

the learned counsel for the petitioners do not support his contention.

Those are on different facts.

4. On hearing the respective counsels, the following

question arises for determination :

(i) Whether the petitioners were public servants ?

(ii) Was the order issuing process against the petitioners was bad in

law for want of sanction under Section 197 of the Criminal Procedure

Code ?

5. Section 197 of the Criminal Procedure Code provides that

no Court shall take cognizance of any offence, except with the

previous sanction of the concerned authority. The Magistrate proceed

to issue summons or warrant as the case may be under Section 204 of

the Criminal Procedure Code only on taking the cognizance.


6. At the time of admission of present writ petition, a

statement was made before the Court that the question whether the

petitioners are public servants is a subject matter for consideration

before the Apex Court in S.L.P. (Cri.) No.7366 of 2007 and connected

Petitions bearing S.L.P (Cri.) No.7338 of 2007. The question whether

they are entitled to seek protection under Section 197 of the Criminal

Procedure Code requires consideration. On these submissions, the

rule was made and ad-interim relief was granted and the record was

called.

7. In Criminal Appeal No.1979 of 2010 arising out of S.L.P.

(Cri.) No.7336 of 2007, no issue was before the Court about sanction

under Section 197 of the Criminal Procedure Code and the appellants

did not claim that they were the public servants.

8. Section 169 of the Electricity Act, 2003 provides that,

members, officers, etc., Appellate Tribunal, appropriate commission to

be public servants. The said Section reads thus :

“169. Members, officers, etc., of Appellate Tribunal,

Appropriate Commission to be public servants.– The

Chairperson, Members, officers and other employees of the

Appellate Tribunal and the Chairperson, Members,

Secretary, officers and other employees of the Appropriate

Commission and the assessing officer referred to in section

126 shall be deemed, when acting or purporting to act in

pursuance of any of the provisions of this Act to be public

servants within the meaning of section 21 of the Indian

Penal Code (45 of 1860). “

9. Apart from members, officers etc., of Appellate Tribunal,

the assessing officer referred to in Section 126 were deemed to be

public servant within the meaning of Section 21 of the Indian Penal

Code.

10. Sub-section (1) of Section 126 of the Electricity Act, 2003

provides that the assessing officer may inspect any place or premises

or after inspection of the equipments, gadgets, machines, devices

found connected or used, or after inspection of records maintained by

any person, the assessing officer comes to the conclusion that such

person is indulging in unauthorized use of electricity, the assessing

officer shall provisionally assess to the best of his judgement the

electricity charges payable by such person or by any other person

benefited by such use.

11. Section 151 of the said Act further provides for the

cognizance of the offence. It provides that, no court shall take

cognizance of an offence punishable under the said Act except upon a

complaint in writing made by Appropriate Government or

Appropriate Commission or any of their officer authorized by them or

a Chief Electrical Inspector or an Electrical Inspector or licensee or the

generating company, as the case may be, for this purpose. However,

by way of amendment, the powers were also conferred upon the

police to investigate the offence.

12. The State Government by various notification appointed

various officers of MSEDCL to detect the theft under Section 135 of

the Electricity Act. The Junior Engineer and the other employees

working on the field were also appointed for the purpose of Section

135. The general practice of assessing the theft of the electricity was,

soon after detecting the theft, the person inspecting the meter or

gadget provisionally assess the amount of theft. The appropriate

government or the MSEB Board has authorized the Junior Engineer

and linemen to find out the theft of the electricity. Since the persons

who were authorized to detect the theft of the electricity and to

provisionally assess the amount of theft, it can be accepted that such

persons are covered under Section 169 of the Electricity Act, 2003.

13. In the old Act of 1948, Section 81 was very specific that

all [members and officers and other employees] of the Board shall be

deemed, when acting or purporting to act in pursuance of any of the

provisions of this Act, to be public servants within the meaning of

section 21 of the Indian Penal Code (45 of 1860).

14. The Madras High Court in V. Srinivasan Vs. The Secretary

and others, Writ Petition No.7424 of 2013 and M.P. Nos.1 and 2 of

2013 had decided the issues raised therein on 25.03.2023. The

question before the Court was whether Section 81 of the 1948 Act

covering all servants and employees of the electricity board as public

servants under Section 21 of the Indian Penal Code, is identical to

Section 169 of the Electricity Act, 2003.

15. It was a case of Prevention of Corruption Act, 1988. It

has been held that Section 169 of the Electricity Act, 2003, is not in

pari materia with Section 81 of the Electricity (Supply) Act, 1948, in

so far as the persons covered by them are concerned. But both

provisions are identical to each other, in so far as the provision of law

on which both revolved, is concerned, namely Section 21 of the

Indian Penal Code.

16. It has been observed in para 19 that as indicated earlier,

the primary contention of the petitioner is that while Section 81 of the

1948 Act, made all employees of the Board as public servants, within

the meaning of Section 21 of the Indian Penal Code, Section 169 of

the Electricity Act, 2003 named only a few Officers as public servants,

within the meaning of Section 21 of the Indian Penal Code. To this

extent, there can be no quarrel with the contention of the learned

counsel for the petitioner, as Section 169 of the 2003 Act is restrictive

than Section 81 of the 1948 Act.

17. In para 20, it has been observed that ‘But that is not the

end of the issue here. Both the 1948 Act and the 2003 Act confined

their applications only to the definition of the expression "public

servant" as found in Section 21 of the Indian Penal Code.’

 

18. Lastly in para 26, it has been observed that ‘therefore, the

reference in Section 169 of the Electricity Act, 2003, making some

Officers as public servants, within the meaning of Section 21 of the

Indian Penal Code, has to be construed as a reference confined only to

offences other than corruption. In so far as the offences of corruption

are concerned, the question whether the employees of the

Corporations carved out of the Electricity Board are public servants or

not, has to be tested only with reference to the definition in Section

2(c) of the Prevention of Corruption Act, 1988 and not with reference

to Section 169 of the Electricity Act, 2003 read with Section 21 of the

Indian Penal Code.’

19. In para 27, it has been further observed that ‘the fact that

Section 169 of the Electricity Act, 2003, restricted the application of

the definition of the expression "public servant" found in Section 21 of

the Indian Penal Code, only to a few Officers, is an indication of only

two things. They are (i) that in so far as offences other than

corruption, punishable even today under the Indian Penal Code are

concerned, only a few Officers named in Section 169 are public

servants; and (ii) that in so far as offences relating to corruption are

concerned, the Electricity Act, 2003 did not deem fit to restrict the

application of the Prevention of Corruption Act only to a few Officers.’

20. In para 28, it has been observed that ‘in other words, in

respect of offences other than corruption, an employee of the

Electricity Corporation, would not be a public servant unless he is

covered by Section 169 of the Electricity Act, 2003.’

21. Section 21 of the Indian Penal Code is comprehensive

which includes various servants as public servants. In Clause 12, the

servants of the local authority, a corporation established by or under a

Central, Provincial or State Act or a Government company as defined

in section 617 of the Companies Act, 1956 (1 of 1956) were also

covered under the definition of the public servants. The MSEDCL is

the government established Board.

22. Section 169 of the Electricity Act, 2003 which defines the

term public servants in pursuance to Section 21 of the Indian Penal

Code includes the servants or the employees under Section 126 of the Electricity Act, 2003. As discussed above, the Board has authorized various officers including the Junior Engineers and linemen to detect the theft. Hence, they are covered under the definition of public servants in Section 169 of the Electricity Act, 2003. Therefore, the Court is of the view that the learned Judicial Magistrate First Class erred in issuing the process against the petitioners without sanction as required under Section 197 of the Criminal Procedure Code. This issue was not dealt with at all. The impugned order also does not reflect the application of mind. Hence, the petition deserves to be allowed. Hence, the following order :

ORDER

A) The writ petition is allowed.

B) The impugned orders of the learned Judicial Magistrate First

Class, Biloli passed in Criminal Case No.114 of 2008 dated

17.06.2008 and learned Additional Sessions Judge, Biloli

passed in Criminal Revision No.17 of 2008 dated 08.09.2008,

stand quashed and set aside.

C) Rule is made absolute in the above terms.

 (S.G. MEHARE, J.)


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