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Issues Involved:
1. Validity of notifications issued by the State Government u/s 5A(1) of the Prevention of Corruption Act, 1947, under the re-enacted Prevention of Corruption Act, 1988. 2. Continuation and effect of these notifications under the 1988 Act. Summary: Issue 1: Validity of Notifications under Section 5A(1) of the 1947 Act The Supreme Court addressed whether the notifications issued by the State Government under Section 5A(1) of the Prevention of Corruption Act, 1947, authorizing Inspectors of Police to investigate corruption cases, are saved under the re-enacted Prevention of Corruption Act, 1988. The High Court had quashed the FIRs and proceedings against the respondents on the grounds that the investigations were not conducted by authorized officers as per Section 17 of the 1988 Act. The Supreme Court found that the notifications issued under the 1947 Act were indeed saved by the re-enacted 1988 Act, as per Section 30(2) of the 1988 Act and Sections 6 and 24 of the General Clauses Act. Issue 2: Continuation of Notifications under the 1988 Act The Supreme Court held that the notifications issued under the 1947 Act continue to be in force under the 1988 Act until they are specifically superseded or withdrawn. The Court emphasized that the provisions of the General Clauses Act, particularly Sections 6 and 24, apply to ensure the continuity of the notifications. The notifications are deemed to have been issued under the 1988 Act, and the investigations conducted by the authorized Inspectors of Police are valid and legal. Conclusion: The Supreme Court concluded that the High Court erred in quashing the proceedings based on the FIRs registered under the 1988 Act. The notifications authorizing Inspectors of Police to investigate corruption cases are valid under the 1988 Act. The appeals were allowed, and the impugned judgments were set aside. The trial courts were directed to proceed with the cases expeditiously.
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