Basdeo And Ors. vs Emperor on 31 January, 1945
6. As has been seen, the learned Magistrate's order is rather cryptically expressed. He stated nothing more than that in his view the necessary sanction had not been duly obtained, but he did not state in what the irregularity consisted. But his reference to a decided case, namely 32 A.I.R. 16, by which was obviously meant the case in Basdeo Aggarwala v. Emperor suggests that he thought that in the present case the necessary sanction had not been obtained before the institution of the prosecution.