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8. I have also noticed that in Paragraph 4, the learned trial court has considered the ratio of judgment rendered in the case of Dr. Subramanian Swamy Vs. Dr. Manmohan Singh reported in [AIR 2012 SC 1185], and the operative part/ instructions are reproduced, herein under :-

"(a) All proposals for sanction placed before any sanctioning authority empowered to grant sanction for prosecution of a public servant under Section 19 of the PC Act must be decided within a period of three months of the receipt of the proposal by the authority concerned.
(c) At the end of the extended period of time-limit, if no decision is taken, sanction will be deemed to have been granted to the proposal for prosecution, and the prosecuting agency or the private complainant will proceed to file the charge-sheet/complaint in the court to commence prosecution within 15 days of the expiry of the aforementioned time-limit."

9. While reading the abovenoted instructions/part of consideration, it is abundantly clear that, these are not the ratio of judgment drawn in the abovenoted case but those are in the form of directions/instructions, framed to be considered by the Parliament, therefore, the findings which are based on the assumption of ratio in judgment of Dr. Subramanian Swamy (supra), is erroneous, on it?s face.

31. Similarly, learned counsel for the complainant had placed reliance on the judgment of this Court in Subramanian Swamy to lend credence to the argument of deemed sanction for prosecution. However, even the said judgment does not in any manner lay down the notion of deemed sanction. First, the said judgment dealt primarily with the Prevention of Corruption Act,1988 and the sanction for prosecution under that Act. Secondly, G.S. Singhvi, J. while penning his separate but concurring opinion in the said judgment, had given some guidelines for the consideration of the Parliament, one of which is to the effect that at the end of the extended period of time limit, if no decision is taken, sanction will be deemed to have been granted to the proposal for prosecution, and the prosecuting agency or the private complainant will proceed to file the chargesheet/complaint in the court to commence prosecution within fifteen days of the expiry of the aforementioned time limit. However, such a proposition has not yet been statutorily incorporated by the Parliament and in such a scenario, this Court cannot read such a mandate into the statute when it does not exist.

13. It is culled out that the impugned order was passed while fixing the date on 24th of October, 2025, for further orders/deemed sanction. The fact remains that the order of sanction dated 20.01.2023 passed by Her Excellency, has already been quashed vide order of this Court dated 18.12.2024 and in compliance thereof, the order of sanction dated 20.01.2023 has formally been cancelled on 12.03.2025 and as a result, there is no sanction of prosecution against the applicant, as of now. This Court has also examined the law rendered in the case of Dr. Subramanian Swamy (supra) which is considered by the learned trial court in the impugned order. From bare reading, which is quoted in the impugned order, itself enough to show that the same is for direction to the Parliament to take note of the aforesaid points and to proceed for promulgating the law in respect thereoff and that is not a guideline framed by the learned Apex Court, to be followed as law precedent and, therefore, the learned trial court has not rightly considered the ratio of judgment rendered, in the present case.