Selvaraja vs The State Rep By Its, on 23 July, 2026

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    Madras High Court

    Selvaraja vs The State Rep By Its, on 23 July, 2026

    Author: G.K.Ilanthiraiyan

    Bench: G.K.Ilanthiraiyan

                                                                                 Crl.O.P.No.28172 of 2024
                                      IN THE HIGH COURT OF JUDICATURE AT MADRAS
    
                                               RESERVED ON :       06.07.2026
    
                                              PRONOUNCED ON : 23.07.2026
    
                                                            CORAM:
    
                                THE HONOURABLE MR. JUSTICE G.K.ILANTHIRAIYAN
    
                                                  Crl.O.P.No.28172 of 2024
                                           and Crl.M.P.Nos.15664 & 15659 of 2024
    
                         P.Selvaraja
                         S/o. A.Ponnusamy,
                         No.213/8, Bhuvaneshwari Nagar,
                         Dharapuram Road,
                         Unjavelampatti PO,
                         Pollachi, Coimbatore.                                      ... Petitioner
    
                                                             Vs.
    
                         1. The State
                         Rep. By the Inspector of Police,
                         Vigilance and Anti-corruption,
                         Coimbatore District.
                         (Crime No.08 of 2021)
    
                         2. C.Sivaji
                         S/o.Chinnasamy,
                         Thalavapalayam Primary Agriculture
                         Co-operative Credit Society,
                         Thondamuthur, Anaimalai Taluk,
                         Coimbatore District.                                       ... Respondents
    
                         Prayer: Criminal Original Petition filed under Section 528 of Bharatiya
                         Nagarik Suraksha Sanhita, 2023, to call for records pertaining to the final
                         report dated 08.03.2024 in Special C.C.3 of 2024 pending on the file fo
                         the learned Special Judge, Special Court, dated 08.03.2024 for cases
    
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                                                                                   Crl.O.P.No.28172 of 2024
                         under the Prevention of Corruption Act and to quash the same by
                         allowing this Criminal Petition.
    
    
                                           For Petitioner   : Mr.Abdukumar Rajarathinam,
                                                              Senior Counsel
                                                              For Mr.Akhil ahmed Akbar Ali
                                           For Respondents
                                                 For R1    : Mr.R.Ganesh Kumar
                                                             Counsel for Government of Tamilnadu
                                                             (Crl.Side)
    
    
                                                            ORDER
    

    This petition has been filed to quash proceedings in

    Spl.C.C.No.3 of 2024 on the file of the learned Special Judge, Special

    SPONSORED

    Court for the cases under the Prevention of Corruption Act, Coimbatore,

    thereby taken cognizance for the offences punishable under Sections 7(a),

    7(a) r/w. 12 of Prevention of Corruption (Amendment) Act, 2018

    (hereinafter referred to as “PC Act”), as against the petitioner.

    Facts of the case :-

    2. The case of the prosecution is that the accused and the

    defacto complainant have been working in different capacities in the

    same co-operative society viz., TP SPL, 25 Thalavaipalayam Primary

    Agricultural Co-operative Credit Society situated in Thondamuthur,

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    Anamalai Taluk, Coimbatore District. While the petitioner was the

    Deputy Registrar and the second accused was the Sub Registrar of the

    Society, the defacto complainant was the Secretary of the credit society

    which had been under the supervision of the petitioner.

    3. While being so, in the year 2021, the Government of Tamil

    Nadu by the G.O.Ms.No.15 and 16 Tamil Nadu Cooperative Food and

    Consumer Department dated 08.02.2021, issued an order to waive off the

    crop loans availed by the farmers from the co-operative society. Pursuant

    to the same, 275 beneficiaries were identified by the defacto complainant

    and in the course of verification, an excess amount of Rs.8,00,000/- was

    found to be disbursed to 17 farmers without complying with the

    procedure. When the issue was raised, the complainant approached the

    Joint Registrar of Cooperative Societies to resolve the issue and the Joint

    Registrar authorized the sanction of waiver to 17 farmers on 14.02.2021.

    4. Thereafter, on 15.02.2021, the petitioner called the defacto

    complainant and asked him to meet him in the office along with the list of

    approved loans. When the defacto complainant met the petitioner and

    appraised him about the issue and informed that the same was resolved

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    Crl.O.P.No.28172 of 2024
    by the Joint Registrar of cooperative societies, the petitioner threatened

    the defacto complainant stating that he is the one who is authorized to

    resolve the discrepancy and also demanded illegal gratification for not

    preparing adverse report against the defacto complainant to the higher

    officials.

    5. Once again, the petitioner contacted the defacto complainant

    and directed him to meet him along with the files relating to the17

    farmers. Accordingly, on 16.02.2021, the defacto complainant met the

    petitioner while he was leaving the office along withthe second accused.

    Therefore, the defacto complainant was directed to meet him the next day

    at about 10.00 a.m. Accordingly, on 18.02.2021, the defacto complainant

    went to the office of the petitioner at 11 am., and met the second accused,

    who told the defacto complainant that the petitioner is the competent

    person to resolve the issue. Thereafter, the second accused informed the

    defacto complainant that the petitioner demanded a sum of Rs.1,25,000/-

    for not taking any action against the defacto complainant. Though the

    defacto complainant attempted to call the petitioner, he could not make it

    and on the next day i.e., on 19.02.2021 at about 9.30 p.m., the second

    accused called the defacto complainant and demanded the bribe and

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    directed the defacto complainant to prepare the report and to meet the

    second accused at Vanjiyapuram Pririvu at 10.00 a.m., on 19.02.2021.

    6. Thereafter, the second accused contacted the defacto

    complainant and informed that the petitioner asked the defacto

    complainant to bring the files of 17 farmers, since the defacto

    complainant failed to comply with the demand. When the defacto

    complainant met the petitioner, he was informed that the enquiry will be

    held against the defacto complainant by appointing the second accused as

    Enquiry Officer. Even thereafter, the second accused once again

    compelled the defacto complainant to comply with the demand. However,

    the defacto complainant was not willing to comply with the demand and

    lodged the complaint alleging that the accused are demanding illegal

    gratification for not initiating any enquiry against the defacto complainant

    under Section 81 of the Tamil Nadu Co-operative Societies Act, 1983.

    7. On receipt of the complaint, the first respondent registered

    the FIR in Crime No.8 of 2021 for the offences punishable under Section

    7(a) r/w Section 12 of the PC Act. Thereafter, the trap laying officer had

    set up a trap andthe defacto complainant met the second accused and had

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    given the tainted amount to the second accused in the presence of shadow

    witnesses at about 7.00 p.m., on 19.02.2021. Thereafter, the accused were

    arrested and remanded to judicial custody. After completion of

    investigation, the first respondent filed final report and the same has been

    taken cognizance by the Trial Court in Spl.C.C.No.03 of 2024.

    Challenging the same, the petitioner filed the present petition.

    Submissions of the counsel appearing for the petitioner: –

    8. The learned Senior Counsel appearing for the petitioner

    submits that even according to the case of the prosecution, the petitioner

    did not receive any bribe amount and it was only the second accused who

    received the bribe amount. The prosecution failed to prove the alleged

    demand and as such the entire proceedings cannot be sustained and is

    liable to be quashed. The present complaint is nothing but a counter blast

    to the enquiry initiated under Section 81 of the Tamil Nadu Co-operative

    Act, as against the defacto complainant for the illegality committed by

    him for the sanction of excess loan amount to 17 farmers.

    8.1. He further submits that the appointing and removing

    authority of the petitioner is the government of Tamil Nadu viz., the
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    Governor of Tamil Nadu. But, the sanction was notaccorded by the

    Governor of Tamil Nadu, under Section 19(1)(b) of the PC Act. The order

    of sanction was signed by the Secretary to the Government. The

    prosecution recorded the statement of the person who signed the sanction

    order under Section 161(3) of Cr.P.C. On perusal of the statement, he had

    stated that he is the competent authority to remove the petitioner and

    thathe had perused all the documents and had applied his mind while

    according the said sanction. He had further stated that on verification of

    documents, he was satisfied that the petitioner should be prosecuted in a

    Court of law for the offence punishable under Section 7(a) of the PC Act.

    Hence, he himself had accorded sanction to prosecute the petitioner

    before the Court of Law.

    8.2. He also contended that as per the order of sanction dated

    18.07.2023, the entire records were perused and it was stated thatthere are

    substantial materials very much available to prosecute the petitioner and

    on satisfaction with the reasons, the Governor of Tamil Nadu had

    accorded sanction to prosecute the petitioner for the offence punishable

    under Section 19 of the PC Act. Though it may seem like the Governor of

    Tamil Nadu himself had accorded sanction, the Secretary to Government

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    had signed the said sanction order. In the usual course of business of

    Government, all the government orders passed by the Governor of Tamil

    Nadu is signed by the Secretary to the concerned department on behalf of

    the Governor of Tamil Nadu. But such a signatory cannot be construed as

    the competent authority to appoint or remove the petitionerfrom his post.

    But the respondent recorded the statement of the Secretary who signed

    the sanction order and as stated previously, the Secretary had spoken as if

    he himself had accorded sanction against the accused. Therefore, the

    order of sanction itself was not accorded in accordance with law as

    contemplated under Section 19(1)(b) of the PC Act. Once the order of

    sanction is found not to be accorded in accordance with law, the entire

    proceedings subsequent to the order of sanction is vitiated and as such the

    entire proceedings is liable to be quashed.

    8.3. In support of his contention, he relied upon the judgment of

    the Hon’ble Supreme Court of India reported in (2013) 3 SCC 1 in the

    case of State of Gujarat &anr., Vs. Justice R.A.Mehta (Retired) &ors.,

    which held as follows :-

    “41. Thus, where the Governor acts as the Head of the
    State, except in relation to areas which are earmarked under
    the Constitution as giving discretion to the Governor, the
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    exercise of power by him must only be upon the aid and
    advice of the Council of Ministers, for the reason that the
    Governor being the custodian of all executive and other
    powers under various provisions of the Constitution is
    required to exercise his formal constitutional powers only
    upon and in accordance with the aid and advice of his
    Council of Ministers. He is, therefore, bound to act under the
    Rules of Business framed under Article 166(3) of the
    Constitution. (Vide Pu Myllai Hlychho v. State of Mizoram.)

    ……………………

    49. The exceptions carved out in the main clause of
    Article 163(1), permit the legislature to entrust certain
    functions to the Governor to be performed by him, either in
    his discretion, or in consultation with other authorities,
    independent of the Council of Ministers. The meaning of the
    words “by or under” is well settled. The expression “by an
    Act”, would mean by virtue of a provision directly enacted in
    the statute in question and that which is conceivable from its
    express language or by necessary implication therefrom. The
    words “under the Act”, would in such context, signify that
    which may not directly be found in the statute itself, but
    which is conferred by virtue of powers enabling such
    action(s) e.g. by way of laws framed by a subordinate law-

    making authority competent to do so under the parent Act.
    (Vide Indramani Pyarelal Gupta v. W.R. Natu.)”

    Hence, he prayed to allow the present Criminal Original Petition.

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    Submissions of the Counsel appearing for the respondent:-

    9. The first respondent filed a counter and the learned

    Government Counsel appearing for the first respondent submits that the

    petitioner is the competent authority to order an enquiry under Section 81

    of the Tamil Nadu Co-operative Societies Act. In order to avoid the said

    enquiry, the petitioner demanded illegal gratification from the defacto

    complainant and directed him to bring the loan waiver list to his office.

    Therefore, the demand was clearly proved by the prosecution. Further,

    the petitioner directed the defacto complainant to hand over the entire

    waiver list to the second accused. Pursuant to the said demand, the trap

    was laid and both the accused were caught red-handed.

    9.1. Insofar as the order of sanction is concerned, the Governor

    of Tamil Nadu, who is the competent authority to accord sanction to

    prosecute the petitioner, perused all the documents and accorded sanction

    to prosecute the petitioner for the offence punishable under Section 7(a)

    of the PC Act. The said sanction order of the Governor was signed by the

    Secretary to the Government. Therefore, the signing authority’s statement

    was recorded under Section 161(3) of Cr.P.C., in which he had stated that

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    he had perused the entire files and that he was satisfied with the materials

    available on records to prosecute the petitioner and accorded sanction. It

    is only prudent to assume that he had given the said statement on behalf

    of the Governor and it doesn’t mean that the signing authority himself

    had accorded the said sanction. That apart, it is only a statement recorded

    under Section 161(3) of Cr.P.C., and it doesn’t vitiate the very sanction

    order which was accorded by the Governor of Tamil Nadu. Further, the

    grounds raised by the petitioner can only be dealt with by the Trial Court

    by letting in evidence during the trial. Hence, he prayed for dismissal of

    the Writ Petition.

    10. Heard the learned counsel appearing on either side and

    perused the materials placed before this Court.

    Issues involved in this case:-

    11. At this junction, this Court finds it imperative to frame the

    following issues pursuant to deciding the case on hand:-

    (i) Whether on record, there exist prima facie materials to attract

    the offences under Section 7(a) of the PC Act against the petitioner?

    (ii) Whether the sanction order accorded to prosecute the accused

    is valid in the eye of law?

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    Issue No.1 :-

    12. There are totally two accused in which the petitioner is

    arrayed as the first accused. The petitioner, while he was working as the

    Deputy Registrar of Co-operative Societies, was the competent officer to

    initiate the enquiry under Section 81 of the Tamil Nadu Co-operative

    Societies Act, against his subordinates, in accordance with G.O.

    (2D)No.109 Co-operation, Food and Consumer Protection Department

    dated 31.08.2005. The second accused was working as Co-operative Sub

    Registrar/Field Officer. Therefore, the first and second accused are the

    public servants under the definition of Section 2(c) of the PC Act. The

    defacto complainant was working as Secretary in TP SPL, 25

    Thalavaipalayam Primary Agricultural Cooperative Credit Society, under

    the administrative control of the petitioner.

    13. While being so, the government passed an order to waive off

    the agricultural crop loans of the farmers vide G.O.Ms.15 Co-operation,

    Food and Consumer Protection Department, dated 08.02.2021. On the

    strength of the government order, 275 eligible farmers of the defacto

    complainant’s society were enlisted by the defacto complainant to avail

    the benefit of waiver of agricultural credit loans and the same was also

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    approved by the Administrative Committee. Subsequently, the list

    prepared by the defacto complainant was verified and it was reported that

    an excessive loan amount was disbursed to 17 loanees in contrary to the

    existing procedures to the tune of Rs.8,00,000/-. When the defacto

    complainant chose to submit his explanation to the Joint Registrar of

    Cooperative Societies, the petitioner objected the defacto complainant

    with ulterior motive, to initiate further enquiry. While being so, on

    14.02.2021, the issue was settled by the Joint Registrar of Cooperative

    Societies, as per the circular issued by the Registrar of Cooperative

    Societies by its proceedings dated 25.10.2017, thereby included 17

    farmers in the list of beneficiaries to avail the benefit of waiver of the

    agricultural credit loans.

    14. Further on 15.02.2021, the petitioner contacted the defacto

    complainant over his phone and enquired about the readiness of loan

    waiver list and directed him to bring the same to his office. The defacto

    complainant submitted the list of beneficiaries to the petitioner and on

    verification of loan waiver beneficiaries list, the petitioner enquired about

    the issue which was already settled by the Joint Registrar of Cooperative

    Department. Though the defacto complainant explained that the issue was

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    already settled by the Joint Registrar of Cooperative Societies, the

    petitioner proclaimed that the issue was not settled and he is the

    competent authority to settle the issue. Further the petitioner demanded

    undue advantage without quoting the quantum for not sending the report

    to the higher officials.

    15. Once again, on 16.02.2021, the petitioner called the defacto

    complainant to bring the loan waiver list to his office. Though the defacto

    complainant went to his office and waited till evening, he met the

    petitioner only at 7.30 p.m., that too while he was leaving the office along

    with the second accused. Thereafter, the second accused informed to the

    defacto complainant that the matter was entrusted to him by the petitioner

    and insisted the defacto complainant to handover the file to him.

    Accordingly, the defacto complainant on 18.02.2021 handed over the

    entire waiver list file and the second accused demanded undue advantage

    of Rs.1,25,000/- for non-initiation of any enquiry proceedings as

    contemplated under Section 81 of the Tamil Nadu Societies Act. On the

    same day, the second accused contacted the defacto complainant and

    reiterated the demand of bribe on behalf of the petitioner. As instructed by

    the petitioner, the second accused received the bribe amount and as such

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    the petitioner charged for the offence under Section 7(a) of the PC Act

    and the second accused charged for the offence under Section 7(a) r/w 12

    of the PC Act. Therefore, there are clenching materials and statement to

    attract the charge under Section 7(a) of the PC Act, as against the

    petitioner.

    16. That apart, even till today, there is no action and enquiry

    initiated by the Cooperative Department as against the defacto

    complainant. Therefore, the issue with regard to excessive loan amount to

    the 17 farmers was completely settled by the Joint Registrar of the

    Cooperative Societies as early as on 14.02.2021 itself. After knowing the

    fact very well that the issue was settled by the Joint Registrar of

    Cooperative Societies, being the Deputy Registrar of the Cooperative

    Societies, who is the competent to initiate the proceedings/enquiry under

    Section 18 of the Tamil Nadu Cooperative Societies Act, the petitioner

    made demand of illegal gratification from the defacto complainant.

    Therefore, the element of mensrea is attracted in the act of the petitioner

    to charge the offence under Section 7(a) of the PC Act.

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    17. Further on 19.02.2021, the second accused met the petitioner

    in his office room and received the information from the defacto

    complainant about the presence of the bribe amount and also received the

    same in the office premises after returning from the chamber of the first

    accused. Further the demand and acceptance of illegal gratification can be

    inferred from the circumstances even in the absence of direct evidences.

    The chain of circumstances available in the case in connection with the

    factum of demand and acceptance is coherent and cogent. Therefore,

    there are ample evidence for proving the dishonest demand and

    acceptance of undue advantage by the petitioner. Therefore, the essential

    elements i.e., demand and acceptance of undue advantage is clearly

    culminated in the case records. The nexus between the first and second

    accused will prove their involvement in the bribe transaction.

    18. The learned Senior counsel appearing for the petitioner

    vehemently contended that even according to the case of the prosecution,

    the petitioner did not receive any bribe amount and on his behalf the

    second accused was the one who received the bribe amount. The recovery

    was also made only from the second accused. Now the petitioner is

    charged for offence punishable under Section 7(a) of the PC Act.

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    Therefore, there is no presumption under Section 20 of the PC Act. In

    support of his contention, he relied upon the judgment of the Hon’ble

    Supreme Court of India reported in 2025 Live Law (SC) 273 in the case

    of Dileepbhai Nanubhai Sanghani Vs. State of Gujarat &anr., which

    held as follows :-

    “22. The only charge is with respect to misuse of
    authority which does not come under the provisions of the
    Prevention of Corruption Act and none of the ingredients
    regarding demand or obtaining or acceptance of bribe or
    any illegal gratification has come out. The accusation
    was only that the policy of the State required a tender
    process to be adopted but the Minister had sanctioned the
    grant of fishing rights on an upset price, which is alleged
    to be misuse of authority especially since the Policy can
    be deviated from, only on orders of the Chief Minister or
    the Cabinet as per the policy document and the Rules of
    Business framed. The investigation report, as we
    observed, speaks only of an allegation of misuse of
    authority, without any allegation of demand and
    acceptance of bribe as against the appellant. The
    presumption under Section 20 of the Act is that, if there is
    a demand and acceptance of bribe, then there is a
    presumption that it is to dishonestly carry out some
    activity by a public servant, for which, first, proof will
    have to be offered of the demand and acceptance. It is not
    otherwise that, if there is a misuse of authority then there
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    is always a presumption of a demand and acceptance of
    bribe, resulting in a valid allegation of corruption.”

    The above judgment is not applicable to the case on hand for the simple

    reason that there are clenching evidences very much available to prove

    that the petitioner demanded illegal gratification for not initiating any

    enquiry/proceedings under Section 81 of the Tamil Nadu Cooperative

    Societies Act, as against the defacto complainant. Hence, the first issue is

    cogently answered in favour of the prosecution.

    Issue No.2:-

    19. The learned Senior Counsel appearing for the accused

    contended that, the Courts are forbidden from taking cognizance of any

    offence punishable under Sections 7, 10, 11, 13 and 15 against a public

    servant except with a previous sanction of the competent authority. In

    support of the same, he relied upon the judgment of the Hon’ble Supreme

    Court of India in “Nanjappa v. State of Karnataka [(2015) 14 SCC

    186]”, the relevant paragraphs of the judgment are extracted hereunder:

    “10. A plain reading of Section 19(1)
    (supra)
    leaves no manner of doubt that the same is
    couched in mandatory terms and forbids courts from
    taking cognizance of any offence punishable under
    Sections 7, 10, 11, 13 and 15 against public servants
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    except with the previous sanction of the competent
    authority enumerated in clauses (a), (b) and (c) to sub-
    section (1) of Section 19. The provision contained in sub-
    section (1) would operate in absolute terms but for the
    presence of sub-section (3) to Section 19 to which we
    shall presently turn. But before we do so, we wish to
    emphasise that the language employed in sub-section (1)
    of Section 19 admits of no equivocation and operates as a
    complete and absolute bar to any court taking
    cognizance of any offence punishable under Sections
    7
    , 10, 11, 13 and 15 of the Act against a public servant
    except with the previous sanction of the competent
    authority.

    ………

    18. The above line of reasoning was followed by
    this Court in State of Goa vs. Babu Thomas (2005) 8 SCC
    130, where this Court while dealing with a case
    under Section 19 of the Prevention of Corruption Act,
    1988 held that absence of a valid sanction under Section
    19(1)
    went to the very root of the prosecution case having
    regard to the fact that the said provision prohibits any
    Court from taking cognizance of any offence punishable
    under Sections 7, 10, 13 and 15 against the public
    servant, except with the previous sanction granted by the
    competent authority in terms of clauses (a), (b) and (c)
    to Section 19(1). This Court was in that case dealing with
    a sanction order issued by an authority who was not
    competent to do so as is also the position in the case at
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    hand.

    ……..

    20. What is important is that, not only was the
    grant of a valid sanction held to be essential for taking
    cognizance by the Court, but the question about the
    validity of any such order, according to this Court, could
    be raised at the stage of final arguments after the trial or
    even at the appellate stage.”
    In view of the above, this Court accepts the contention of the petitioner’s

    counsel that the sanction order accorded by a non-competent authority

    would result in the nullity of the trial or legal proceedings against the

    accused and that the validity of a sanction order shall be questioned at the

    very inception or even at the appellate stage and there is no quarrel over

    the said argument.

    20. However, it was vehemently contended by the learned

    Senior Counsel for the petitioner that in the case on hand, the sanctioning

    authority had no competence to accord sanction to prosecute the accused.

    He stated that the Secretary to the Government had signed the sanction

    order on behalf of the Governor which is an order executed by the State

    Government. It was further stated that where the Governor acts as the

    Head of the State, except in relation to areas which are earmarked under

    the Constitution as giving discretion to the Governor, the exercise of
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    power by him, must only be upon the aid and advice of the Council of

    Ministers, for the reason that the Governor, being the custodian of all

    executive and other powers under various provisions of the Constitution,

    is required to exercise his formal Constitutional powers, only upon, and

    in accordance with, the aid and advice of his Council of Ministers. He is,

    therefore, bound to act under the Rules of Business framed under Art. 166

    (3) of the Constitution. In support of the said contention, the learned

    senior counsel relied upon the judgment of the Hon’ble Supreme Court of

    India in the case of State of Gujarat v. R.A. Mehta reported in (2013) 3

    SCC 1.

    21. At this juncture, it is relevant to refer to the Tamil Nadu

    Government Business Rules and Secretariat Instructuions, 1978,

    wherein, Rules 7, 11 and 12(1) are relevant and are extracted hereunder:

    “7. the Council shall be collectively responsible for
    all executive orders issued in the name of the Governor in
    accordance with these rules, whether such orders are
    authorized by an individual minister on a matter
    appertaining to his portfolio or as the result of discussion
    at a meeting of the council or otherwise.

    ….

    11. All orders or instruments made or executed by
    or on behalf of the Government of the State shall be
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    Crl.O.P.No.28172 of 2024
    expressed to be made or executed in the name of the
    Governor.

    12.(1). Every order or instrument of the
    Government of the State shall be signed either by the
    Chief Secretary, a Secretary, a Special Secretary and
    Additional Secretary, a Joint Secretary, a Deputy
    Secretary or an Under Secretary to the Government of
    the State or such other officer as may be specially
    empowered in that behalf in the manner specified below
    and such signature shall be deemed to be the proper
    authentication of such order or instrument.

    “By order and in the name of the Governor of Tamil
    Nadu
    (signature)
    Name and designation of the officer authorized to sign”.

    22. It was his contention that, the Secretary to the Government,

    who had signed the sanction order, in his 161(3) statement, had stated that

    he had perused all the documents and that he had gotten necessary

    clarification and had accorded sanction to prosecutethe accused under

    Section 19(1)(b) of the PC Act and the same is invalid as these statements

    would mean that he had not acted on behalf of the Governor rather it

    would mean that he had acted in his personal capacity.

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    Crl.O.P.No.28172 of 2024

    23. Proceeding on the said statement, it was further contended

    that the Governor neither has discretionary power nor can he delegate

    such powers to a subordinate authority in the matter of granting sanction

    and is constitutionally bound to act only on the aid and advice of the

    Council of Ministers under Article 163 of the Constitution. Therefore,

    according to the appellant, the sanction order is rendered non est in law.

    The above stated contention advanced by the Learned Senior Counsel

    does not merit acceptance.

    24. It is an admitted fact that the accused herein was an

    employee of the State and comes under Section 19(1)(b) of the PC Act.

    As per Section 19(1)(b) of the PC Act, a person who is or was an

    employee of the State at the time of commission of the alleged offence

    shall not be removed from his office without the sanction of the

    Government of the concerned State. According to Article 166 of the

    Indian Constitution and the Corresponding Tamil Nadu Business Rules,

    all executive actions of the Government of a State shall be expressed to

    be taken in the name of the Governor. On a keen perusal of both the

    provisions, i.e, Article 166 of the Indian Constitution and Section 19(1)

    (b) of the PC Act, it can be seen that there is no explicit mention that the
    Page 23 of 34

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    Crl.O.P.No.28172 of 2024
    Governor himself has to accord a sanction or that the Secretary to the

    Government is not a competent authority to accord such a sanction. What

    is mandatory is that all the executive actions shall be expressed to be

    taken in the name of Governor.

    25. Article 166(2) of the Constitution of India states that Orders

    and other instruments made and executed in the name of the Governor

    shall be authenticated in such manner as may be specified in rules to be

    made by the Governor, and the validity of an order or instrument which is

    so authenticated shall not be called in question on the ground that it is not

    an order or instrument made or executed by the Governor.

    26. On perusal of the sanction order, it can be clearly seen that

    the order was accorded only in the name of or by the Governor and it was

    duly authenticated as provided under the Tamil Nadu Business Rules

    wherein the Secretary to the Government had signed the same. It is well

    settled that under Articles 154, 163 and 166 of the Constitution of India,

    executive actions of the State are taken in the name of the Governor,

    while the actual exercise of executive functions is carried out through

    officers duly authorized under the Rules of Business framed under Article

    166(3) of the Constitution of India.

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    Crl.O.P.No.28172 of 2024

    27. The Governor is the constitutional head of the State and

    ordinarily acts on the aid and advice of the Council of Ministers.

    Consequently, an order authenticated and issued by the Secretary to

    Government in accordance with the above stated constitutional scheme is,

    in the eye of law, an act of the State Government. The Secretary only acts

    as an authorized functionary of the Government and such an action as

    indicated by the Constitution of India under Article 166(2) shall not be

    called in question on the ground that it is not an order or instrument made

    or executed by the Governor.

    28. Even if such a constitutional or statutory interpretation is

    false, the validity of a sanction cannot be determined merely by an

    isolated statement made during the course of investigation by the signing

    authority i.e., the Secretary to the Government herein, particularly when

    the sanction order itself unequivocally discloses that it was issued by the

    Governor in exercise of the powers vested under Article 166(1) and

    Section 19(1)(b) of the PC Act. The statement of the Secretary under

    Section 161 Cr.P.C. cannot override, alter or diminish the legal effect of

    an official order issued in accordance with law.

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    Crl.O.P.No.28172 of 2024

    29. Even assuming that the Secretary, while giving his statement

    under Section 161 Cr.P.C., loosely described the grant of sanction as one

    accorded by him personally, such an expression cannot be read divorced

    from the constitutional and statutory framework governing governmental

    action. A witness’s understanding or description of the legal character of

    an official act cannot determine its validity. What is of relevance is

    whether the sanction emanated from the competent authority through the

    prescribed legal procedure and whether the order bears the necessary

    authentication as required under Article 166 of the Constitution and the

    applicable Rules of Business.

    30. The argument that the Governor himself could not have

    exercised discretion in granting sanction also does not advance the

    appellant’s case. The sanction order nowhere suggests that it was the

    Governor acting in his individual discretion. On the contrary, the order is

    an executive action of the State Government issued in the name of the

    Governor and authenticated by the Secretary in accordance with the

    constitutional mandate. Such executive action carries the presumption of

    regularity, and in the absence of cogent evidence demonstrating any

    constitutional or statutory infraction in the decision-making process, the

    Court cannot invalidate the sanction on speculative assumptions.
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    Crl.O.P.No.28172 of 2024

    31. It is equally settled that the validity of a sanction is to be

    tested on the touchstone of competence of the authority and due

    application of mind to the materials placed before it. The appellant has

    not demonstrated that the Secretary to the Government lacks competence

    or that the sanction was granted mechanically without consideration of

    the relevant records. The entire challenge rests solely upon an isolated

    statement of the Secretary made during investigation, which is wholly

    insufficient to invalidate an otherwise valid sanction order. This Court

    finds no infirmity in the sanction order and the contention that the

    sanction is null and void on the ground that it was allegedly accorded by

    the Secretary not on behalf of the Governor, or that it offends the

    constitutional scheme governing the exercise of executive power by the

    Governor, is devoid of merit and is, therefore, rejected.

    32. In this regard, it is relevant to rely upon the judgment of the

    Hon’ble Supreme Court of India in the case of “Shivendar kumar v.

    State of Maharashta [(2001) 9 SCC 303]” wherein it was held as

    follows:

    “As noted earlier, Section 6(1)(b) is applicable in the
    present case. The said provision does not specify any
    particular officer as the competent authority to grant
    sanction. It only states that the State Government, without
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    Crl.O.P.No.28172 of 2024
    whose sanction the delinquent officer cannot be removed
    from office/post, is the competent authority to pass the order
    of sanction. From the Sanction Order, which is available on
    the record, it is clear that the Secretary, Medical Education
    Department passed/signed the order of sanction of
    prosecution against the appellant on behalf of the Governor.
    It is not the case of the appellant that the Secretary had no
    authority to act on behalf of the State Government. It follows
    that the order of sanction in the present case was passed by
    the Secretary of the Medical Education Department with the
    authority of the Governor of the State Government. No
    material on record has been brought to our notice to show
    that the Governor had issued any order authorising an
    officer other than the Secretary of the Department to pass
    order of sanction in the case. If that was the case, then the
    appellant should have produced the order or at least raised
    the contention that an Officer other than the Secretary had
    been authorised for that purpose. No such material appears
    to have been produced. When the Secretary was being
    examined in support of the Sanction Order passed by him
    such question was also put to him. Reliance is placed on a
    sentence in his deposition that he is not the authority to
    remove the appellant. This statement, without further
    material, cannot from the basis of the contention that the
    Secretary, Medical Education Department was not
    competent to pass the order of sanction on behalf of the State
    Government. The Government functions through its officers.
    The Secretary is the Head of the Department and the
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    Crl.O.P.No.28172 of 2024
    Principal Officer representing the State Government in the
    concerned Department. Unless specific material is produced
    to show that some other officer was competent to deal with
    the matter of sanction of prosecution against the appellant it
    can be reasonably assumed that the Secretary of the
    Department is the competent authority to pass the order of
    sanction. The object of Section 6 or for that matter Section
    197
    of the Criminal Procedure Code, which is a pari materia
    provision, is that there should be no unnecessary harassment
    of a public servant; the idea is to save the public servant
    from the harassment which may be caused to him if each and
    every aggrieved or disgruntled person is allowed to institute
    a criminal complaint against him. The protection is not
    intended to be an absolute and unqualified Immunity against
    criminal prosecution. In a case where it is seen that a
    Sanction Order has been passed by an authority who is
    competent under the law to represent the State Government,
    the burden is heavy on the party who challenges the
    authority of such order to show that the authority competent
    to pass the order of sanction is somebody else and not the
    officer who has passed the Sanction Order in question.”

    33. Section 6 of the old Act corresponds to Section 19 of the

    new Act, and even in Section 19, the provision does not specify any

    particular officer as the competent authority to grant sanction. It only

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    Crl.O.P.No.28172 of 2024
    states that the State Government, without whose sanction the delinquent

    officer cannot be removed from office. Therefore, in this case, the

    Secretary of the government had accorded the sanction order on behalf of

    the Governor. Further, as stated above, the intention of the provision is to

    save innocent public servant from unwanted legal proceeding and the

    same shall not be misunderstood as an absolute and unqualified immunity

    against criminal prosecution. However, on perusal of the materials

    available on record, this court finds a prima facie case against the accused

    and the Secretary to the Government, being a competent authority, had

    gone into the same and had signed the sanctioning order on behalf of the

    Governor and this Court finds no infirmity in the sanction order and

    deems the action of the sanctioning authority competent and fit.

    Accordingly, the second issue is also answered in favour of the

    prosecution.

    34. Further, it is relevant to rely upon the judgments of the

    Hon’ble Supreme Court of India in the judgment reported in 2019 (4)

    SCC 351 in the case of Devendra Prasad Singh Vs. State of Bihar

    &Anr., (Crl.A.No.579 of 2019 dated 02.04.2019) while dealing with the

    petition to quash the entire criminal proceedings held that the High

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    Crl.O.P.No.28172 of 2024
    Courts have no jurisdiction to appreciate the statement of the witnesses

    and record a finding that there were inconsistencies in their statements

    and therefore, there was no prima facie case made out as against the

    accused. It could be done only by the trial Court while deciding the issues

    on the merits or/and by the Appellate Court while deciding the appeal

    arising out of the final order that the charge sheet has been laid on the

    basis of the inconsistency statement under 180 of the Bharatiya Nagarik

    Suraksha Sanhita, 2023.

    35. Further, the Hon’ble Supreme Court of India in the judgment

    reported in 2019 (10) SCC 686in the case of Central Bureau of

    Investigation Vs. Arvind Khanna, (Crl.A.No.1572 of 2019 dated

    17.10.2019) held that the High Courts cannot record the findings on the

    disputed facts. The defence of the accused is to be tested after

    appreciation of evidence by the trial Court during the trial. Therefore, this

    Court has no power to consider the disputed facts under Section 528 of

    the Bharatiya Nagarik Suraksha Sanhita, 2023.

    36. The Hon’ble Supreme Court of India in another judgment

    dated 02.12.2019 passed in Crl.A.No.1817 of 2019 in the case of

    M.Jayanthi Vs. K.R.Meenakshi&anr, held that while considering the
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    Crl.O.P.No.28172 of 2024
    petition for quashment of complaint or charge sheet, the Court should not

    embark upon an enquiry into the validity of the evidence available. All

    that the Court should see is as to whether there are allegations in the

    complaint which form the basis for the ingredients that constitute certain

    offences complained of. Further, the Court can also see whether the

    preconditions requisite for taking cognizance have been complied with or

    not and whether the allegations contained in the complaint, even if

    accepted in entirety, would not constitute the offence alleged. Whether

    the accused will be able to prove the allegations in a manner known to

    law would arise only at a later stage i.e., during trial.

    37. Further this Court cannot observe at this stage as to whether

    the initiation of criminal proceeding itself is malicious or not. The same is

    required to be considered at the conclusion of the trial. Therefore, the

    grounds raised by the petitioner to quash the final report/charge sheet

    cannot be entertained. Therefore, this Court is not inclined to quash the

    proceedings in Spl.C.C.No.3 of 2024 on the file of the learned Special

    Judge, Special Court for the cases under the Prevention of Corruption

    Act, Coimbatore.

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    Crl.O.P.No.28172 of 2024

    38. Accordingly, the Criminal Original Petition stands

    dismissed. Consequently, connected miscellaneous petitions are also

    closed.

    
    
    
    
                                                                                                23.07.2026
                         Index            : Yes/No
                         Neutral citation : Yes/No
                         Speaking/non-speaking order
    
                         rts
    
    
                         To
    
                         1. The Special Judge,
                         Special Court for the cases under
                         the Prevention of Corruption Act,
                         Coimbatore.
    
                         2.The Inspector of Police,
                         Vigilance and Anti-corruption,
                         Coimbatore District.
    
                         3. The Public Prosecutor,
                         Madras High Court,
                         Chennai.
    
    
    
    
                         Page 33 of 34
    
    
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                                                             Crl.O.P.No.28172 of 2024
                                                    G.K.ILANTHIRAIYAN. J,
    
                                                                                 rts
    
    
    
    
                                                                       Order in
                                                       Crl.O.P.No.28172 of 2024
                                         and Crl.M.P.Nos.15664 & 15659 of 2024
    
    
    
    
                                                                      23.07.2026
    
    
    
    
                         Page 34 of 34
    
    
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