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2026 Supreme(Online)(Mad) 36975

IN THE HIGH COURT OF JUDICATURE AT MADRAS
A.D. Jagadish Chandira, J
V.R. Rambhad – Appellant
Versus
The Tamil Nadu State represented by the Deputy Director Industrial Safety and Health – Respondent


Advocates:
For the Appellants/Petitioners: Mr. P.T. Ramkumar
For the Respondents: Mr. K.M.D. Muhilan, Additional Public Prosecutor

Table of Content
1. factory inspection revealed safety violations leading to prosecutions. (Para 2)
2. petitioners argue limitation, lack of sanction, ignored replies. (Para 3)
3. respondent counters on timely filing, consideration of replies, no sanction needed. (Para 4)
4. prior sanction under section 197 cr.p.c. mandatory for central government employees. (Para 6 , 7 , 8 , 9 , 14)
5. supreme court precedents distinguished; factual fit essential. (Para 10 , 11 , 12 , 13)
6. proceedings quashed for want of prior sanction; petitions allowed. (Para 15 , 16 , 17)

COMMON ORDER

In view of commonality of issues involved, all the four criminal original petitions are considered and decided by this common order.

2. A bird’s eye view of the facts that led to the filing of the present four criminal original petitions is as under:

2.1. While the petitioner in Crl.O.P. Nos.26475 and 26594 of 2025 (Rambhad) is an Occupier in the Heavy Vehicles Factory which is a unit of Armoured Vehicles Nigam Ltd., the petitioner in Crl.O.P.Nos.26438 and 26504 of 2025 (Jay Prakash Singh) is a Manager in the same organisation.

2.2. On 23.08.2023 at 10.00 a.m., on a joint inspection made by the Joint Director and Deputy D

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