R.S. Nayak vs A.R. Antulay & Anr on 17 April, 1986 In R.S.Nayak's case (supra), the Supreme Court considered the scope and effect of the expression discharged used in Sections 227, 239 and 245 Cr.P.C. The ratio is as follows : Supreme Court of India Cites 45 - Cited by 548 - P N Bhagwati - Full Document