Conviction Under Prevention of Corruption Act Is Set Aside As Court Finds Prosecution Case Not Proved Beyond Reasonable Doubt

A bench of Justices Sudhanshu Dhulia and Ahsanuddin Amanullah heard an appeal by a Revenue Inspector-convict challenging the High Court of Telangana’s affirmation of his conviction under Sections 7 and 13(1)(d)/13(2) of the Prevention of Corruption Act, 1988. The appeal arose from allegations that the accused officer demanded and accepted a bribe of Rs.2,000 while conducting an inquiry into compensation for drought‑affected trees.

The Court allowed the appeal, set aside the conviction and sentence and quashed the judgments of the courts below. The Court found material contradictions in the prosecution case and concluded that the guilt of the appellant was not proved beyond reasonable doubt, entitling him to the benefit of doubt. The Court noted established principles that “the test is whether the [evidence] inspires confidence in the mind of the court” and relied on authorities holding that minor discrepancies should not be given undue emphasis but serious contradictions may vitiate the prosecution’s case. The Court, in its reasoning, observed: “Thus, on an overall circumspection of the facts and circumstances of the case, the evidence on record and for reasons stated above, we find that the guilt of the Appellant has not been proved beyond reasonable doubt. Having found so, this is a case where benefit of doubt was required to be given to the Appellant.” The Court further recorded that “Even otherwise, where demand has not been proved, Section 20 will also have no application.”

Background The appellant, then a Revenue Inspector posted in Gundala Mandal, Nalgonda District, was accused of demanding Rs.2,000 from a complainant who sought compensation for trees damaged by drought. The complainant filed a complaint with the Anti‑Corruption Bureau on 08.08.2003 and a trap was laid on 11.08.2003. The trap party alleged that the complainant placed the marked currency in a rexine bag attached to the petrol tank of the appellant’s motorcycle; tests on the appellant’s hands allegedly proved negative, but the marked notes were recovered from the bag. The Trial Court convicted the appellant on 29.01.2008 and sentenced him to one year RI and fines for offences under Section 7 and Section 13(1)(d) r/w 13(2) of the Act. The High Court dismissed the criminal appeal on 06.03.2024, holding that demand and acceptance were proved beyond reasonable doubt.

Before this Court, the appellant argued that the essentials of a trustworthy trap case — prior verification of demand, use of a shadow witness and successful pH test — were absent; he pointed to contradictions in the complainant’s and other witnesses’ testimonies and urged that animus between the parties rendered the prosecution story suspect. The State relied on the sequence of trap proceedings, the recovery of marked notes and submitted that the absence of third‑party witnesses to a clandestine demand was not fatal. The Court examined the record, observed material contradictions in witness accounts (including differing narrations by the complainant and his wife, and inconsistent sequences relating to who placed the money and whether the appellant handled it), and applied settled precedents on evaluation of witness credibility and benefit of doubt. The Court referred to Yogesh Singh v Mahabeer Singh and Krishnegowda v State of Karnataka on the distinction between minor discrepancies and contradictions that go to the root of the prosecution case, and to Om Parkash v State of Haryana regarding the inapplicability of presumptions under Section 20 where demand was not proved.

The Court concluded that the prosecution had not established the offence beyond reasonable doubt and therefore the presumption under Section 20 did not militate against the appellant. It allowed the appeal, set aside conviction and sentence, quashed the judgments of the courts below, and directed that any deposited fine be refunded within four weeks. The appellant was granted the benefit that no further surrender orders were required as he had already been exempted from surrender.

Case Details: Case No.: 2025 INSC 655 (Criminal Appeal / Special Leave Petition (Criminal) No.6066/2024) Case Title: Paritala Sudhakar v. State of Telangana Appearances: For the Petitioner(s): [Names/designations not specified in the judgment] For the Respondent(s): [Names/designations not specified in the judgment]