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The State by Lokayuktha Police v. K. Rangayya

Criminal Appeal · 2026 INSC 574Decided 26 May 2026
Crl.A. No.-002917-002917 - 2026
Justice Sanjay Karol · Justice Nongmeikapam Kotiswar Singh

Background

A Police Sub-Inspector (Respondent No. 1) allegedly seized a complainant's two-wheeler and mobile phone on a false pretext, and over several months allegedly orchestrated a bribe demand through associates for their return, eventually telling the complainant to "do something for those boys" when nothing had been given to him directly. The complainant approached the Karnataka Lokayukta Police, an FIR was registered under Section 7(a) of the Prevention of Corruption Act, and a bribe amount was later recovered from a person connected to the officer. The Karnataka High Court quashed the FIR against the officer, holding there was no direct demand or acceptance of money by him personally, prompting the State to appeal to the Supreme Court.

Decision Breakdown

The Supreme Court held that the High Court had effectively conducted an impermissible "mini-trial" at the pre-trial, FIR-quashing stage, when no evidence had yet been led or examined. It clarified that Section 7(a) of the PC Act criminalises even an "attempt" to obtain an undue advantage, not just actual receipt of money, and that under Explanation 2 to the section, it is immaterial whether the advantage is sought for oneself, another person, or through a third party. The circumstantial evidence, including recorded conversations and recovery of the bribe amount from a person connected to the officer, was material that needed to be tested at trial, not pre-empted by quashing. The Court also rejected the officer's mala fide and departmental-exoneration defences as issues for trial, not for the quashing stage, set aside the High Court's order, and restored the FIR and all proceedings for the trial court to continue in accordance with law, while clarifying its observations do not determine final guilt.

Lesson Learnt

An FIR under anti-corruption law cannot be quashed merely because there was no direct, in-person demand or acceptance of a bribe by the accused official: an attempt to obtain an advantage through intermediaries can also fall within Section 7(a) of the PC Act, and courts should not weigh evidence or conduct a "mini-trial" at the FIR-quashing stage; that is for the trial itself.

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

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