As per case facts, police officers (applicants) are challenging a criminal case and process issued against them. The complainant alleged police atrocities and grievous injuries while in custody during an ... investigation for obstructing official duty. A Magistrate's initial order under Section 323 IPC was revised to Section 326 IPC by an Additional Sessions Judge due to fracture injury. The applicants contend that prior government sanction under Section 197 CrPC is essential as their actions were connected to official duty. The question arose whether prior government sanction is required for police officers' actions, even if excessive, if they are reasonably connected to their official duties. Finally, the High Court ruled that the police officers' actions, though grave and in excess, were under "colour of duty" and "purporting to act in discharge of official duty", thus requiring sanction under Section 197 CrPC. The criminal case and process were quashed, allowing the complainant to pursue after obtaining proper sanction.