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State of Lokayuktha Police v. C B Nagaraj

Criminal Appeal · 2025 INSC 736Decided 19 May 2025
Crl.A. No.-001157-001157 - 2015
Justice Pankaj Mithal · Justice Ahsanuddin Amanullah

Background

The respondent, an Extension Officer in a Taluka Panchayath in Karnataka, was accused of demanding Rs. 1,500 from a complainant to forward a spot-inspection report needed for a validity certificate. A Lokayuktha trap caught the respondent allegedly accepting the marked currency. The trial court convicted him under the Prevention of Corruption Act, but the Karnataka High Court acquitted him on appeal, and the State challenged that acquittal before the Supreme Court.

Decision Breakdown

The Supreme Court scrutinized the complainant's and a key witness's testimony and found serious inconsistencies: the witness gave contradictory accounts of whether he overheard the demand, and the complainant admitted the spot-inspection report had, by the prosecution's own version, already been forwarded before the money changed hands, undercutting the claim that the bribe was demanded as consideration for that pending work. Since the "demand", an essential link in the chain along with acceptance and recovery, was not proved beyond reasonable doubt, the statutory presumption of guilt under Section 20 of the Act could not be invoked. The Court held the acquittal was not perverse and dismissed the State's appeal.

Lesson Learnt

In bribery prosecutions, mere recovery of tainted money is not enough for conviction. The prosecution must independently prove the demand for the bribe beyond reasonable doubt before any legal presumption of guilt can operate against the accused.

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

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