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Union of India & Ors. vs Major R. Metri No.-08585N

Criminal Appeal · 2022 INSC 384Decided 4 Apr 2022
Criminal Appeal No. 2196 of 2017

Background

Major R. Metri, an army Recruiting Medical Officer, was court-martialled and convicted of taking illegal gratification (bribes) to clear medically unfit recruits at army recruitment rallies, and sentenced to dismissal from service and rigorous imprisonment. The Armed Forces Tribunal set aside this corruption conviction but instead convicted him of a lesser Army Act offence based on the same facts, sentencing him only to loss of seniority and a severe reprimand, and ordered his reinstatement without back pay. Both the Union of India (seeking to restore the corruption conviction) and Major Metri (challenging even the lesser conviction) appealed to the Supreme Court.

Decision Breakdown

The Supreme Court examined the evidence and found that the two sums of money the prosecution alleged were bribes had been credibly explained as an unrelated loan given to help the officer travel home for his daughter's birth, and a separate loan repayment routed through his father-in-law's account, not payments for clearing unfit recruits. It also held that the extra-judicial confession relied on by the prosecution was uncorroborated and could not sustain a conviction on its own. The Court dismissed the Union's appeal (upholding the acquittal on the corruption charge) and allowed Major Metri's appeal, quashing the lesser conviction too, acquitting him of all charges, and ordering full reinstatement with continuity of service, though without back wages for the period he was out of service.

Lesson Learnt

An extra-judicial confession is inherently weak evidence and cannot support a conviction unless corroborated by other reliable evidence; financial transactions between colleagues cannot be presumed to be bribes simply because of timing, if they have a credible, innocent explanation.

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

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