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Criminal LawSupreme Court of India

Madan Lal v. State of Rajasthan

Criminal Appeal · 2025 INSC 340Decided 7 Mar 2025
Crl.A. No.-001247-001247 of 2025 (@ SLP(Crl.) No. 6895 of 2022, with connected SLP)
Justice Sudhanshu Dhulia · Justice K. Vinod Chandran

Background

Madan Lal, an Enforcement Inspector, and a co-accused Office Assistant in the Supply Department were convicted under the Prevention of Corruption Act for demanding and accepting a bribe from a trader (PW-5) applying for a trade licence. A trap was laid by the Anti-Corruption Bureau after the complainant alleged repeated bribe demands. Both the Trial Court and the Rajasthan High Court upheld the conviction, relying mainly on official witnesses since the independent witnesses to the trap had turned hostile.

Decision Breakdown

The Supreme Court acquitted both accused, finding the prosecution had failed to prove demand and acceptance of the bribe beyond reasonable doubt. It noted glaring inconsistencies in the complainant's own account of the amount demanded, and that the two independent witnesses to the trap (who turned hostile) both stated they entered the room only after the money had allegedly already changed hands, contradicting the official witnesses' version that they saw the handover. Given this reasonable doubt on the core facts, the statutory presumption of guilt under Section 20 of the Act could not be invoked.

Lesson Learnt

A bribery conviction cannot rest on inconsistent testimony and a trap narrative that independent witnesses do not corroborate; the presumption of guilt in corruption cases only kicks in once demand and acceptance of the bribe are proved beyond reasonable doubt in the first place.

Madan Lal v. State of Rajasthan – Legal Case Shots | LegalAware