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In Ninge Gowda and Another v S. Madhureswar, it is held by this Court that the need for sanction need not be considered as soon as the complaint is lodged. In Prabhakar V. Sinari v Shanker Anant Verlekar , the Deputy Superintendent of Police threatened the complainant that he would arrest him if he interfered with the hawkers and asking hawkers to enter upon land and the complainant also threatened that he would be slapped. The prosecution was launched against the Superintendent of Police on various charges. Under those circumstances their Lordships have held that no sanction was required. In State of Maharashtra v Atma Ram and Others, it is held that protection from the alleged acts of beating and confinement done by police officer sanction is not necessary because there is no connection between such acts and duties imposed on an officer. Under such circumstances, the police officer is not entitled for protection under Sections 161(1) and 64(b) of Bombay Police Act. In Shambhoo Nath Misra v State of Uttar Pradesh and Others, while considering Section 197(1) of the Cr. P.C. it is held that fabrication of records and misappropriation of public funds by public servant is not the official duty and sanction for his prosecution for alleged offence not necessary.