Apparently, the bar contained in Section 197 of the Code would not be attracted to the aforesaid facts and circumstances of the present case simply because the police officers had exceeded their authority in proceeding to arrest the accused persons at Criminal Appeal @ S.L.P.(Crl.) No.4517 of 2019 Anuppur which was not within the territorial jurisdiction of the Mahila Police Station of Jabalpur. They ought to have contacted the local police; apprised the local police officials of the matter and solicited their assistance in effecting arrest of the accused persons.” Going by the assertions in the complaint filed by the appellant, prima facie, it appears that without any authority, the first respondent, along with other police personnel, entered the house of the appellant early in the morning and committed the offences alleged against them. Looking at the nature of the allegations in the complaint, at this stage, it is impossible to conclude that the acts allegedly done by the first respondent were committed by her while acting or purporting to act in the discharge of her official duty. Therefore, at this stage, we cannot conclude that a sanction under Section 197 of Cr.P.C. was required.
[S.M. Mansoori v. Surekha Parmar, (2023) 6 SCC 156]