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Aman Bhatia v. State (GNCT of Delhi)

Criminal Appeal · 2025 INSC 618Decided 2 May 2025
Crl.A. No.-002613-002613 - 2014
Justice J.B. Pardiwala · Justice R. Mahadevan

Background

The appellant, a licensed stamp vendor at the Sub-Registrar's office in Janakpuri, Delhi, was accused of demanding Rs. 12 instead of Rs. 10 for a stamp paper. On a complaint to the Anti-Corruption Branch, a trap was laid with marked currency notes, and the appellant was allegedly caught accepting the tainted money. The trial court and the Delhi High Court both convicted him under the Prevention of Corruption Act, holding that a stamp vendor is a "public servant" for the purposes of the Act.

Decision Breakdown

The Supreme Court agreed on the legal point, since stamp vendors perform an important public duty and receive government-regulated remuneration (a discount on stamp purchases), they do qualify as "public servants" under Section 2(c)(i) of the Act. However, on the facts, the Court found the prosecution's evidence riddled with problems: the key panch witness could not recall whether the appellant had actually demanded the excess amount, the Raid Officer admitted he did not hear the alleged demand, there was an unexplained three-hour delay before the investigating officer was called to the scene, and since the tainted currency included the legitimately-owed Rs. 10 note along with the alleged Rs. 2 bribe, the phenolphthalein reaction could not conclusively prove acceptance of a bribe specifically. Because demand was not proved beyond reasonable doubt, the presumption of guilt under Section 20 could not apply, and the conviction was set aside.

Lesson Learnt

Qualifying as a "public servant" under anti-corruption law is only the first hurdle: a conviction still requires the prosecution to prove the demand and acceptance of a bribe beyond reasonable doubt with clear, consistent evidence; legal status alone cannot substitute for that proof.

Official source (sci.gov.in)View Judgment (PDF)

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