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P K Pradhan vs The State Of Sikkim Represented By The on 24 July, 2001

28. When facts of the present case are examined, then it being a matter of evidence as held by Hon'ble Supreme Court in the cases of Parveen Sultana & P.K. Pradhan (supra) and the similar is the ratio of the law laid down by the Hon'ble Supreme Court in the case of Ram Sagar Vs. Central Bureau of Investigation, 2025 LiveLaw (SC) 891, wherein it is held that the issue of sanction to prosecute under Section 197 of Cr.P.C. depends on the nature of the evidence presented by the prosecution during trial, and when that ratio is taken into consideration, then it is evident that under the facts and circumstances of the case in Sheetla Sahai and others (supra), facts, being different, judgment of Hon'ble Supreme Court in the case of Ram Sagar (supra) will have application, therefore, it will be subject-matter of final adjudication as to whether under the facts and circumstances, sanction under Section 197 of Cr.P.C. was required or not.
Supreme Court of India Cites 20 - Cited by 224 - B N Agrawal - Full Document

Station House Officer ... vs B.A. Srinivasan on 5 December, 2019

In Station House Officer v. B.A. Srinivasan (supra), it has been held that; "the issue whether the alleged act is intricately connected in discharge of official function and whether the matter would come within the expression "while acting or purporting to act in discharge of their official duty", would at times get crystalized only after evidence is led and issue of sanction can be agitated at the later stage as well."
Supreme Court of India Cites 34 - Cited by 25 - U U Lalit - Full Document
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