https://www.scconline.com/blog/post/2021/01/20/ker-hc-there-is-no-requirement-that-the-proceeding-in-relation-to-which-the-offence-has-been-committed-shall-be-pending-at-the-time-of-filing-an-application-under-s-340-1-of-the-code-petition-al/
Ker HC | There is no requirement that the proceeding in relation to which the offence has been committed shall be pending at the time of filing an application under S. 340 (1) of the Code; Petition allowed