In Brief
A doctor in Jammu & Kashmir was investigated for allegedly purchasing sub-standard medical kits at inflated prices under the National Rural Health Mission scheme, violating government procurement norms. The High Court quashed the FIR and criminal proceedings, holding that the delegation of investigative authority lacked reasoned justification, prior magistrate sanction was required for conspiracy charges, and the preliminary enquiry violated anti-corruption principles. The Supreme Court allowed the State's appeal, ruling that (1) authorization orders need not provide detailed reasons if application of mind is evident; (2) when cognizable offences under the Prevention of Corruption Act are coupled with non-cognizable conspiracy charges, no prior magistrate sanction is required for investigating the substantive offences; (3) preliminary enquiry to determine prima facie case is permissible and does not constitute investigation; and (4) the Vigilance Manual rule governing preliminary enquiry is valid and consistent with CrPC provisions.
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