State through CBI, New Delhi v. Jitender Kumar Singh
Background
Two prosecutions raised the question whether a corruption Special Judge could continue ordinary criminal charges against private accused after the public servant died. In one, charges had already been framed and the joint trial had begun. In the other, the public servant died before any relevant charges were framed.
Decision Breakdown
The Court allowed both appeals but distinguished those stages. A Special Judge who had begun the corruption trial and exercised power to try connected ordinary offences retained that power after the public servant's death. The Delhi matter therefore had to continue before the Special Judge. In the Mumbai matter, no corruption trial had begun and the private accused faced no independent corruption offence, so the ordinary charges belonged before the competent magistrate. Both proceedings were directed to be completed within six months.
Lesson Learnt
A public servant's death does not automatically end connected proceedings against private accused. The proper court depends on the charged offences and whether the corruption trial had already begun.