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Puneet Sabharwal vs CBI

Not available · 2024 INSC 221Decided 19 Mar 2024
Not available
Justice Vikram Nath · Justice K.V. Viswanathan

Background

R.C. Sabharwal, a former Additional Chief Architect at the New Delhi Municipal Corporation, was chargesheeted in 1995 for allegedly amassing assets disproportionate to his known income between 1968 and 1995, with his son Puneet Sabharwal accused of helping him route these assets through trusts and firms using proceeds from encashed Special Bearer Bonds. Both had unsuccessfully challenged the framing of criminal charges against them before the Delhi High Court and came to the Supreme Court arguing that certain Income Tax proceedings had exonerated them and that the charges should be quashed at this preliminary stage.

Decision Breakdown

The Supreme Court dismissed both appeals, holding that the threshold for framing a criminal charge is low, only a strong suspicion based on the material on record is needed, not proof beyond reasonable doubt, which is reserved for trial. It distinguished the Income Tax exoneration relied upon by the appellants, noting those proceedings dealt with income assessment, not the specific question of disproportionate assets and unaccounted sources of income under the Prevention of Corruption Act, so they could not be used to short-circuit the criminal case. The Court also rejected the argument that Puneet Sabharwal's minority during part of the check period should shield him, since he was an adult for the last seven years of the relevant period, and directed that the 25-year-old pending trial be concluded expeditiously, by 31 December 2024.

Lesson Learnt

Being cleared in income tax or other regulatory proceedings does not automatically clear a person of a separate corruption charge testing whether their assets are disproportionate to known income; courts will not conduct a "mini-trial" at the charge stage and will let a case proceed to trial if there is enough material to raise a genuine suspicion.

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

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