CRR-1011-2016 (O&M) -:1:-

IN THE HIGH COURT OF PUNJAB AND HARYANA

AT CHANDIGARH

CRR-1011-2016 (O&M)

Reserved on :- 05.08.2026

Date of Pronouncement:-14.08.2026

Uploaded on:- 14.08.2026

Dr. Rajesh Kumar Verma

… Petitioner

Versus

Manish

... Respondent

****

CORAM: HON'BLE MR. JUSTICE VIRINDER AGGARWAL

Argued by :-

Mr. P.S. Ahluwalia, Senior Advocate with

Mr. Keerat Dhillon, Advocate

for the petitioner.

Mr. A.P. Bhandari, Advocate with

Ms. Bhargavi, Advocate

for the respondent.

****

VIRINDER AGGARWAL , J .

1. The present criminal revision petition has been preferred

assailing the legality and correctness of the order dated 03.02.2016,

whereby the learned Trial Court has directed the framing of charge against

the petitioner for the offence punishable under Section 218 of the Indian

Penal Code in Criminal Complaint No.487 dated 18.05.2004, instituted

under Sections 161, 165-A, 166, 167, 218, 219, 323, 330, 342, 506, 464,

465, 468, 471 and 120-B of the Indian Penal Code, read with Sections 5(2)

and 5(1)(d) of the Prevention of Corruption Act, at the instance of the

complainant-respondent. The petitioner prays for setting aside the

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impugned order on the ground that the same is contrary to law and the

material available on record.

2. Briefly stated, the case of the complainant is that he is a

resident of Village Baghola, Tehsil Palwal, and had completed his Bachelor

of Arts in the year 2003. It is alleged that a long-standing dispute regarding

ancestral property was pending between his father and his paternal uncle,

Lachhi Ram, who allegedly harboured animosity towards the complainant's

family and was determined to deprive them of their lawful share.

According to the complainant, Lachhi Ram, in connivance with certain

private persons, had earlier instituted false criminal cases against him and

his family with a view to harass and pressurise them.

2.1. It is further alleged that, pursuant to the complainant having

secured bail in those cases, Lachhi Ram conspired with the other accused

persons and succeeded in getting registered FIR No.270 dated 17.05.2003

under Sections 342, 363, 366-A, 376 and 34 IPC and the relevant

provisions of the SC/ST Act by falsely implicating the complainant in a

fabricated criminal case. The complainant asserts that, at the relevant time,

he was present before the Court of the learned SDM, Palwal, in separate

proceedings, thereby establishing his false implication.

2.2. The complainant further alleges that on 17.05.2003, he was

arrested from his residence during the early hours of the morning by the

police officials and was thereafter subjected to illegal detention and severe

custodial torture with the object of extracting a false confession in the

aforesaid case. It is alleged that despite suffering multiple injuries, the

concerned police officials, in connivance with the attending medical

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officer, manipulated the medical examination and procured a false medical

report under coercion. Dissatisfied therewith, the complainant's father

approached the competent Court, which directed that the complainant be

medically examined by a Board of Doctors. Alleging that the entire

sequence of events was the result of a criminal conspiracy involving the

private accused, police officials and others, the complainant instituted the

present complaint seeking appropriate legal action against all the accused

persons. During trial proceedings vide impugned order charge under

Section 218 IPC was framed against petitioner who conducted medical

examination of accused in discharge of his official duties. That has has

been assailed in revision.

3. Learned counsel for the petitioner submits that the principal

question arising for consideration in the present revision petition is

‘whether the petitioner, who was admittedly a public servant at the relevant

point of time, could have been prosecuted for the offence punishable under

Section 218 of the Indian Penal Code, 1860 without obtaining the

mandatory previous sanction under Section 197 of the Code of Criminal

Procedure, 1973’?

3.1. Elaborating the aforesaid contention, learned counsel submits

that the petitioner was serving as a Medical Officer and had medically

examined the accused strictly in the discharge of his official duties. Upon

such examination, the petitioner recorded that no fresh external injuries

were found on the person of the accused. Since the accused disputed the

said medical opinion, the competent Court subsequently directed

constitution of a Board of Doctors, which, upon re-examination, noticed

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certain contusions and tenderness on the body of the accused. Merely

because the opinion expressed by the Medical Board differed from that of

the petitioner, criminal proceedings came to be initiated against him.

3.1. It is vehemently contended that the entire allegation against

the petitioner emanates exclusively from an act performed by him in the

lawful discharge of his official functions as a Government Medical Officer.

The preparation of the medico-legal report was intrinsically connected with

his official duties and is based upon his opinion and, therefore, the

institution of criminal proceedings against him, in the absence of the

mandatory previous sanction contemplated under Section 197 of the Code

of Criminal Procedure, 1973, is legally impermissible and vitiates the very

prosecution. Consequently, it is argued that the impugned order directing

framing of charge cannot be sustained in law and deserves to be set aside.

3.2. In support of the aforesaid submissions, learned counsel has

placed reliance upon the judgments rendered in D. Devaraja vs. Owais

Sabeer Hussain, 2020(7) SCC 695; Amal Kumar Jha vs. State of

Chhattisgarh, 2016(2) R.C.R. (Criminal) 910; Mishri Chand vs.

Satender, 2018(1) R.C.R. (Criminal) 147; and Dr. Manish Bansal vs.

State of Haryana, 2019(1) R.C.R. (Criminal) 963.

3.3. Learned counsel for the petitioner has further relied upon the

recent judgment of the Hon'ble Supreme Court in Directorate of

Enforcement vs. Bibhu Prasad Acharya etc., 2024 INSC 843, to contend

that the protection envisaged under Section 197 of the Code of Criminal

Procedure, 1973 has been construed broadly even in proceedings under the

Prevention of Money Laundering Act, wherever the alleged acts bear a

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reasonable nexus with the discharge of official duties. It is submitted that

the ratio of the aforesaid decision fortifies the petitioner's contention that,

in the absence of a valid sanction under Section 197 Cr.P.C., the

prosecution itself is rendered legally unsustainable. The Hon'ble Supreme

Court has observed as under:-

14. A Bench of three Hon'ble Judges of this Court in the case of P.K.

Pradhan v. State of Sikkim5, in paragraphs 5 and 15 held thus:

"5. The legislative mandate engrafted in sub-section (1) of Section

197 debarring court from taking cognizance of an offence except

with the previous sanction of the Government concerned in a case

where the acts complained of are alleged to have been committed

by a public servant in discharge of his official duty or purporting to

be in the discharge of his official duty and such public servant is

not removable from office save by or with the sanction of the

Government, touches the jurisdiction of the court itself. It is a

prohibition imposed by the statute from taking cognizance.

Different tests have been laid down in decided cases to ascertain

the scope and meaning of the relevant words occurring in Section

197 of the Code: "any offence alleged to have been committed by

him while acting or purporting to act in the discharge of his official

duty". The offence alleged to have been committed must have

something to do, or must be related in some manner, with the

discharge of official duty. No question of sanction can arise under

Section 197, unless the act complained of is an offence; the only

point for determination is whether it was committed in the

discharge of official duty. There must be a reasonable connection

between the act and the official duty. It does not matter even if the

act exceeds what is strictly necessary for the discharge of the duty,

as this question will arise only at a later stage when the trial

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proceeds on the merits. What a court has to find out is whether the

act and the official duty are so interrelated that one can postulate

reasonably that it was done by the accused in the performance of

official duty, though, possibly in excess of the needs and

requirements of the situation"

"15. Thus, from a conspectus of the aforesaid decisions, it will be

clear that for claiming protection under Section 197 of the Code, it

has to be shown by the accused that there is reasonable connection

between the act complained of and the discharge of official duty.

An official act can be performed in the discharge of official duty as

well as in dereliction of it. For invoking protection under Section

197 of the Code, the acts of the accused complained of must be

such that the same cannot be separated from the discharge of

official duty, but if there was no reasonable connection between

them and the performance of those duties, the official status

furnishes only the occasion or opportunity for the acts, then no

sanction would be required. If the case as put forward by the

prosecution fails or the defence establishes that the act purported to

be done is in discharge of duty, the proceedings will have to be

dropped. It is well settled that question of sanction under Section

197 of the Code can be raised any time after the cognizance;

maybe immediately after cognizance or framing of charge or even

at the time of conclusion of trial and after conviction as well. But

there may be certain cases where it may not be possible to decide

the question effectively without giving opportunity to the defence

to establish that what he did was in discharge of official duty. In

order to come to the conclusion whether claim of the accused that

the act that he did was in course of the performance of his duty was

a reasonable one and neither be to the of pretended nor fanciful,

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can examined during the course of trial by giving opportunity

defence to establish it. In such an eventuality, the question sanction

should be left open to be decided in the main judgment which may

be delivered upon conclusion of the trial."

(emphasis added)

Thus, there is no embargo on considering the plea of absence of

sanction, after cognizance is taken by the Special Court of the offences

punishable under Section 4 of the PMLA. In this case, it is not necessary

to postpone the consideration of the issue.

15. We have carefully perused the allegations against the respondents

in the complaint. The allegation against the second respondent is

of allocating an additional 10 lakh litres of water to India Cement

Ltd. Taking the averments made in the complaint against him as it

is, the act alleged against him has been committed by him while

purporting to act in the discharge of his official duties. The

allegation against the first respondent is of the allotment of land

measuring 250 acres to M/s. Indu Tech Zone Private Ltd. Taking

the averments made in the complaint as correct, the act alleged

against him has been done by him purporting to act in the

discharge of his official duties. In the case of both respondents, the

acts alleged against them are related to the discharge of the duties

entrusted to them. It is not even the allegation in the complaints

that the two respondents were not empowered to do the acts they

have done. There is a connection between their duties and the acts

complained of. The second condition for the applicability of

Section 197(1) also stands satisfied, and therefore, in this case,

Section 197(1) of CrPC applies to the respondents, assuming that

Section 197(1) of CrPC applies to the proceedings under the

PMLA.”

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3.4. Learned counsel for the petitioner has further placed reliance

upon the judgment of the Hon'ble Supreme Court in Suneeti Toteja vs.

State of U.P. and Others, 2025(2) R.C.R. (Criminal) 138, to reinforce

the contention that where the alleged acts of a public servant bear a

reasonable nexus with the discharge of official duties, compliance with the

mandate of Section 197 of the Code of Criminal Procedure, 1973 is a

condition precedent to the institution and continuance of criminal

proceedings. It is submitted that the ratio laid down in the aforesaid

decision lends substantial support to the petitioner's case that, in the

absence of a valid and prior sanction under Section 197 Cr.P.C., the

impugned order framing charge is rendered legally unsustainable. The

Hon'ble Supreme Court has held as under:-

29. As per the aforementioned proposition, it is only to be seen if the

accused public servant was acting in the performance of his/her

official duties, and if the answer is in the affirmative, then prior

sanction for their prosecution is a condition precedent to the

cognizance of the cases against them by the courts. It is therefore

largely a disputed question of fact here and not a question of law.

However, this fact of appellant herein acting in her official

capacity is not seriously contested by the respondents herein. In

the instant case, the appellant had filed the counter affidavit and

interacted with the complainant in her capacity of a Presiding

Officer, ICC. The correctness of the allegations with regard to the

conduct of the appellant need not be ascertained herein by this

Court but the fact that she was acting in her official duty is

sufficient to hold that a prior sanction from the department was in

fact necessary before the Magistrate taking cognizance against her.

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The Magistrate therefore erred in proceeding to take cognizance

against the appellant without the sanction for prosecution being

received from BIS, and since BIS has eventually refused to grant

sanction for the prosecution of the appellant, the prosecution

against the appellant could not have been sustained.

3.5. On the strength of the aforesaid submissions and the judicial

precedents relied upon, learned counsel for the petitioner contends that the

prosecution initiated against the petitioner, in the absence of the mandatory

previous sanction under Section 197 of the Code of Criminal Procedure,

1973, is legally untenable. It is, therefore, prayed that the impugned order

dated 03.02.2016 directing the framing of charge against the petitioner be

set aside and the present criminal revision petition be allowed.

4. Per contra, learned counsel appearing for the respondent has

vehemently opposed the present revision petition and contended that the

protection envisaged under Section 197 of the Code of Criminal Procedure,

1973 is not available to the petitioner in the facts and circumstances of the

present case. It is submitted that the allegation against the petitioner is not

merely of an error in the discharge of official duties, but of having

deliberately prepared a false medico-legal report with the intent to shield

the accused and thereby facilitate the commission of an offence. According

to the learned counsel, such acts cannot be regarded as having been

committed in the bona fide discharge of official functions so as to attract

the statutory protection under Section 197 Cr.P.C. Consequently, it is

argued that no previous sanction was required before initiating the

prosecution against the petitioner.

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4.1. In support of the aforesaid submissions, learned counsel has

placed reliance upon the judgments rendered in Rajib Ranjan and Others

vs. R. Vijay Kumar, 2014(4) R.C.R. (Criminal) 723; Inspector of Police

and Another vs. Battenapatla Venkata Ratnam and Another, 2015(3)

R.C.R. (Criminal) 86; S.B. Saha and Others vs. M.S. Kochar, 1979 AIR

(SC) 1841; Sachin @ Sachinder @ Satendra vs. State of U.P. and

Another, 2017(5) R.C.R. (Criminal) 305; and Bhawna Bai vs.

Ghanshyam and Others, 2020(1) R.C.R. (Criminal) 370.

4.2. Learned counsel for the respondent has further placed strong

reliance upon the recent judgment of the Hon'ble Supreme Court in Om

Prakash Yadav vs. Niranjan Kumar Upadhyay and Others, 2024 INSC

979, wherein the scope, ambit and applicability of Section 197 of the Code

of Criminal Procedure, 1973 have been comprehensively examined. It is

submitted that the Hon'ble Supreme Court, after an exhaustive survey of

the precedents governing the field, has delineated the principles governing

the requirement of prior sanction and has laid down the following guiding

parameters:-

(i) The object behind the enactment of Section 197 CrPC is to

protect responsible public servants against institution of

possibly false or vexatious criminal proceedings for offences

alleged to have been committed by them while they are acting

or purporting to act in their official capacity. It is to ensure that

the public servants are not prosecuted for anything which is

done by them in the discharge of their official duties, without

any reasonable cause. The provision is in the form of an

assurance to the honest and sincere officers so that they can

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perform their public duties honestly, to the best of their ability

and in furtherance of public interest, without being demoralized.

(ii) The expression “any offence alleged to have been committed by

him while acting or purporting to act in the discharge of his

official duty" in Section 197 CrPC must neither be construed

narrowly nor widely and the correct approach would be to strike

a balance between the two extremes. The section should be

construed strictly to the extent that its operation is limited only

to those acts which are discharged in the "course of duty".

However, once it has been ascertained that the act or omission

has indeed been committed by the public servant in the

discharge of his duty, then a liberal and wide construction must

be given to a particular act or omission so far as its "official"

nature is concerned.

(iii) It is essential that the Court while considering the question of

applicability of Section 197 CrPC truly applies its mind to the

factual situation before it. This must be done in such a manner

that both the aspects are taken care of viz., on one hand, the

public servant is protected under Section 197 CrPC if the act

complained of falls within his official duty and on the other,

appropriate action be allowed to be taken if the act complained

of is not done or purported to be done by the public servant in

the discharge of his official duty.

(iv) A public servant can only be said to act or purport to act in the

discharge of his official duty, if his act is such that it lies within

the scope and range of his official duties. The act complained of

must be integrally connected or directly linked to his duties as a

public servant for the purpose of affording protection under

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Section 197 CrPC. Hence, it is not the duty which requires an

examination so much as the "act" itself.

(v) One of the foremost tests which was laid down in this regard

was whether the public servant, if challenged, can reasonably

claim that, what he does, he does in virtue of his office.

(vi) Later, the test came to be re-modulated. It was laid down that

there must be a reasonable connection between the act done and

the discharge of the official duty and the act must bear such

relation to the duty such that the accused could lay a reasonable,

but not a pretended or fanciful claim, that his actions were in the

course of performance of his duty. Therefore, the sine qua non

for the applicability of this section is that the offence charged,

be it one of commission or omission, must be committed by the

public servant either in his official capacity or under the color of

the office held by him such that there is a direct or reasonable

connection between the act and the official duty.

(vii) If in performing his official duty, the public servant acts in

excess of his duty, the excess by itself will not be a sufficient

ground to deprive the public servant from protection under

Section 197 CrPC if it is found that there existed a reasonable

connection between the act done and the performance of his

official duty.

(viii) It is the "quality" of the act that must be examined and the mere

fact that an opportunity to commit an offence is furnished by the

official position would not be enough to attract Section 197

CrPC.

(ix) The legislature has thought fit to use two distinct expressions

"acting" or “purporting to act". The latter expression means that

even if the alleged act was done under the color of office, the

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protection under Section 197 CrPC can be given. However, this

protection must not be excessively stretched and construed as

being limitless. It must be made available only when the alleged

act is reasonably connected with the discharge of his official

duty and not merely a cloak for doing the objectionable act.

(x) There cannot be any universal rule to determine whether there is

a reasonable connection between the act done and the official

duty, nor is it possible to lay down such a rule. However, a “safe

and sure test" would be to consider if the omission or neglect on

the part of the public servant to commit the act complained of

would have made him answerable for a charge of dereliction of

his official duty. If the answer to this question is in the

affirmative, the protection under Section 197 CrPC can be

granted since there was every connection with the act

complained of and the official duty of the public servant.

(xi) The provision must not be abused by public servants to

camouflage the commission of a crime under the supposed color

of public office. The benefit of the provision must not be

extended to public officials who try to take undue advantage of

their position and misuse the authority vested in them for

committing acts which are otherwise not permitted in law. In

such circumstances, the acts committed must be considered

dehors the duties which a public servant is required to discharge

or perform.

(xii) On an application of the tests as aforesaid, if on facts, it is prima

facie found that the act or omission for which the accused has

been charged has a reasonable connection with the discharge of

his official duty, the applicability of Section 197 CrPC cannot

be denied.

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4.3. Relying upon the aforesaid judicial precedents and the

submissions advanced, learned counsel for the respondent contends that the

acts attributed to the petitioner cannot be said to have been performed in

the bona fide discharge of his official duties so as to attract the protective

umbrella of Section 197 of the Code of Criminal Procedure, 1973. It is,

therefore, submitted that the prosecution is not vitiated for want of prior

sanction and that the impugned order does not suffer from any legal

infirmity warranting interference in the exercise of revisional jurisdiction.

Accordingly, it is prayed that the present criminal revision petition, being

devoid of merit, be dismissed.

5. I have heard learned counsel for the parties at considerable

length and have meticulously perused the record as well as the judicial

precedents relied upon by the learned counsel appearing on either side,

with their able assistance.

6. In D. Devaraja’s case (supra), the Hon’ble Supreme Court

has authoritatively enunciated the legal position to the effect an offence

committed entirely outside the scope of the duty of the police officer, would

certainly not require sanction. To cite an example, a police man assaulting

a domestic help or indulging in domestic violence would certainly not be

entitled to protection. However if an act is connected to the discharge of

official duty of investigation of a recorded criminal case, the act is

certainly under colour of duty, no matter how illegal the act may be.

6.1. The allegations against the petitioner are that, on 18.05.2003,

one Munish was produced before him for medico-legal examination

pursuant to the directions issued by the learned Court. Upon examining the

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said Munish, the petitioner recorded in the Medico-Legal Report that no

fresh external injury was found on his person. The said opinion, however,

was disputed by Munish, who, through his father, moved an application

before the learned Judicial Magistrate First Class, Palwal, seeking his re-

examination by a duly constituted Medical Board. The said application was

allowed vide order dated 19.05.2003. In compliance thereof, the Medical

Board conducted the medico-legal examination of Munish on 21.05.2003

and recorded the following injuries on his person:-

1.Tenderness present over the terminal PIP joint of Lt. middle

finger. Movements full range but painful. No ext. mark of injury

seen.

Advised X-ray Lt. Hand.

2.Complaining of pain on the outer border of left foot. Blackish

contusion over 5

th

metatarsal. Tenderness over base of 5

th

metatarsal.

Advised X-ray.

3.Reddish black contusion 4" × ½" Lt. deltoid region.

4.Reddish black contusion 5 cm × 2 cm Lt. buttock region.

6.2. The Medical Board assessed the probable duration of the

injuries to be between 24 and 96 hours. It is on the strength of the opinion

rendered by the Medical Board that the present prosecution came to be

instituted against the petitioner on the allegation that he had intentionally

submitted a false Medico-Legal Report by omitting to record the external

injuries found on the person of Munish, allegedly with the object of

extending undue favour to the police officials concerned.

6.3. It is not in dispute that the medico-legal examination

conducted by the petitioner preceded the examination undertaken by the

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Board of Doctors. While the petitioner opined that no fresh external injury

was noticed on the person of Munish, the Medical Board, upon its

subsequent examination, noticed certain contusions, tenderness and

complaint of pain, which were not reflected in the Medico-Legal Report

prepared by the petitioner. Whether such omission was deliberate and

actuated by mala fides, as alleged by the prosecution, or was merely an

error of medical judgment or opinion, is undoubtedly a matter falling

within the domain of evidence and is an issue to be adjudicated by the trial

Court upon appreciation of the material brought on record.

7. However, the pivotal question arising in the present revision

petition is not whether the petitioner had intentionally furnished an

incorrect Medico-Legal Report, but whether the alleged act was committed

by him while acting or purporting to act in the discharge of his official

duties, thereby attracting the protective umbrella of Section 197 of the

Code of Criminal Procedure, 1973.

7.1. In the present case the question is with regard to correctness

by the opinion expressed by the petitioner with regard to the medical

examination of the complainant and the same has been assailed in the trial

on the grounds Board of Doctors in their examination subsequently on

19.05.2003 has found contusions and tenderness and concluded that fresh

injuries were present. It is a matter of common knowledge that contusions

sometime are not immediately visible and takes some time in manifestation

and in some cases the same can take 24 hours or more as per medical

jurisprudence, a contusion (bruise) is an injury caused by blunt force

trauma that ruptures subcutaneous blood vessels without breaking the skin.

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A late manifestation refers to when a bruise does not appear immediately

on the skin surface; it can take 24 to 48 hours (and sometimes longer for

deep tissue or visceral contusions) to become fully visible, distinct, and

measurable for forensic evaluation. The medico-legal examination of

Munish was conducted by the petitioner pursuant to the directions of the

competent Court and in his capacity as a Medical Officer discharging his

official functions. The preparation of the Medico-Legal Report constituted

an integral and inseparable component of his official duties. Even

assuming, for the sake of argument, that the allegations levelled by the

prosecution are accepted at their face value, the omission to record certain

injuries is inextricably linked with, and has a direct and reasonable nexus

to, the discharge of the petitioner's official functions. The alleged act

cannot be divorced from his official duties so as to deprive him of the

statutory protection contemplated under Section 197 Cr.P.C.

7.2. It is well settled that where the act complained of bears a

reasonable nexus with the discharge of official duties, the protection under

Section 197 Cr.P.C. is attracted, notwithstanding the allegation that such

act was performed improperly, negligently or even with an oblique motive.

The correctness or otherwise of the Medico-Legal Report and the

culpability, if any, of the petitioner are matters to be adjudicated during

trial; however, the competence of the Court to take cognizance itself

remains contingent upon the existence of a valid sanction where the

statutory requirement is attracted.

7.3. Since the alleged acts attributed to the petitioner were

committed while acting in the discharge of his official duties and are

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intrinsically connected therewith, previous sanction of the competent

authority under Section 197 of the Code of Criminal Procedure, 1973, was

a condition precedent for taking cognizance by Court. Admittedly, no such

sanction was obtained before the institution of the criminal proceedings.

Consequently, the cognizance by Court against the petitioner suffers from a

fundamental legal infirmity and is rendered unsustainable in the eyes of

law.

7.4. Accordingly, the present revision petition deserves to succeed

and is hereby allowed. The impugned order dated 03.02.2016, whereby the

petitioner was directed to face trial for the offence punishable under

Section 218 of the Indian Penal Code, 1860, is hereby set aside.

8. In view of the final adjudication of the present revision

petition, all pending miscellaneous applications, if any, arising out of or

ancillary to the present proceedings shall also stand disposed of. Since the

principal lis has attained finality by virtue of this judgment, no separate or

further orders are called for in respect of the aforesaid applications, the

same having been rendered infructuous.

( VIRINDER AGGARWAL )

14.08.2026 JUDGE

Gaurav Sorot

Whether reasoned / speaking?Yes / No

Whether reportable? Yes / No