In Brief
The appellant sought investigation and FIR registration against public servants for alleged corruption in a drinking water project. The Special Judge rejected the complaint, holding that prior sanction under Section 19 of the Prevention of Corruption Act was mandatory even for the investigative stage under Section 156(3) of the CrPC. The Supreme Court identified a conflicting jurisprudence: established precedents hold that Section 156(3) operations are pre-cognizance and do not require sanction, while recent judgments held otherwise. The Court referred the matter to a larger bench to settle this fundamental conundrum. It also struck off Respondent No. 1 from the proceedings as he was wrongly arrayed and had no substantive involvement.
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