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P. Somaraju vs The State of Andhra Pradesh

Not available · 2025 INSC 1263Decided 28 Oct 2025
Not available
Justice Prashant Kumar Mishra · Justice Joymalya Bagchi

Background

The appellant, an Assistant Commissioner of Labour, was accused of demanding and accepting a Rs. 3,000 bribe from a labour contractor (the complainant) in exchange for renewing contract-labour licences, leading to a trap operation by the Anti-Corruption Bureau in 1997. The Trial Court acquitted him, citing numerous inconsistencies in the prosecution's case, including contradictory testimony about the sequence of events, a hostile witness who claimed he was pressured by ACB officials, a negative sodium-carbonate ("hand-wash") chemical test on the appellant's fingers, and defence evidence suggesting the complainant planted the money while the appellant was momentarily away from his office. The Andhra Pradesh High Court reversed the acquittal and convicted him under Sections 7 and 13(1)(d)/13(2) of the Prevention of Corruption Act.

Decision Breakdown

The Supreme Court restored the acquittal, reiterating the well-settled principle that an acquittal carries a "double presumption" of innocence, and an appellate court can only overturn it if the trial court's view was perverse or legally unsustainable, not merely because another view is also possible. It found the Trial Court's reasoning sound and well-supported: the prosecution's demand-and-bribe narrative was undermined by the complainant's own admissions, contradictions among witnesses, a hostile witness's retraction, and a negative chemical test, while the appellant's defence (that he had lawfully required inspection of records and was away from his desk when the money was placed) was plausible. The Court held the High Court had failed to engage with these evidentiary gaps and had simply substituted its own inferences. It also criticised the High Court's finding that the appellant's request for register inspection was a "creative" corrupt device, noting an Assistant Commissioner of Labour is statutorily empowered to demand such inspection.

Lesson Learnt

Once a trial court has acquitted an accused based on a reasoned evaluation of contradictory or unreliable evidence, an appellate court cannot reverse that acquittal simply because it would have weighed the same evidence differently. It must show the trial court's view was actually perverse or impossible on the record.

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

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