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Matajog Dobey vs H. C. Bhari(With Connected Appeal) on 31 October, 1955

Otherwise the entire purpose of affording protection to a public servant without sanction shall stand frustrated. For instance a police officer in discharge of duty may have to use force which may be an offence for the prosecution of which the sanction may be necessary. But if the same officer commits an act in course of service but not in discharge of his duty and without any justification therefor then the bar under Section 197 of the Code is not attracted. To what extent an act or omission performed by a public servant in discharge of his duty can be deemed to be official was explained by this Court in Matajog Dobey v. H. C. Bhari, AIR (1956) SC 44 thus:
Supreme Court of India Cites 16 - Cited by 666 - Full Document

Kalicharan Mahapatra vs State Of Orissa on 4 August, 1998

When the newly-worded section appeared in the Code (Section 197) with the words "when any person who is or was a public servant" (as against the truncated expression in the corresponding provision of the old Code of Criminal Procedure, 1898) a contention was raised before this Court in Kalicharan Mahapatra v. State of Orissa [1998] 6 SCC 411 that the legal position must be treated as changed even in regard to offences under the Old Act and New Act also. The said contention was, however, repelled by this Court wherein a two-Judge Bench has held thus:
Supreme Court of India Cites 20 - Cited by 86 - Full Document
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