Supreme Court observed that the High Court cannot reverse the findings recorded by the Special Court in Corruption Cases on the validity of sanction without demonstrating how a failure of justice had occurred to the accused. The case, titled "State of Karnataka Lokayukta Police vs S. Subbegowda," involved the discharge of the accused from offenses charged under Section 13(1)(e) read with Section 13(2) of the Prevention of Corruption Act, 1988.

The issues raised in the appeal by the State were whether the High Court, under Section 482 of the Criminal Procedure Code (CrPC), could discharge the accused from charges despite the trial having progressed significantly and witnesses being examined in support of the prosecution's case. The other issue was whether the High Court could reverse the Special Court's findings on the validity of sanction, given the bar contained in Section 19(3) read with Section 19(4) of the Prevention of Corruption Act.

The bench of Justices Aniruddha Bose and Bela M. Trivedi observed that Section 19(3) and (4) of the Act explicitly state that no finding, sentence, or order passed by the Special Judge shall be reversed or altered on the ground of the absence of, or any error, omission, or irregularity in the sanction, unless a failure of justice has actually occurred. 

The Court clarified that the provisions apply to proceedings in appeal, confirmation, or revision, and not to proceedings before the Special Judge. Therefore, the appellate or revisional court can only interfere with the Special Judge's order if it finds that the absence of, or any error, omission, or irregularity in the sanction has resulted in a failure of justice.

Furthermore, the Court held that an interlocutory application seeking discharge in the midst of trial is not maintainable once cognizance has been taken by the Special Judge and charges have been framed against the accused. In this case, the issue of the validity of the sanction was raised earlier but not pressed for. The Court emphasized that the accused should have raised the issue during the final arguments in the trial.

Based on these observations, the Supreme Court allowed the appeal in favor of the State of Karnataka, discharging the accused from the charges levied against him under the Prevention of Corruption Act. The ruling sets a precedent for how courts should handle cases involving the validity of sanction and emphasizes the importance of considering any failure of justice before reversing or altering findings in such cases.

Case titled: State of Karnataka Lokayukta Police vs S. Subbegowda