Supreme Court acquits public servants in bribery case due to reasonable doubt: Madan Lal vs. State of Rajasthan (2025) INSC 340 (7 March 2025)

Date of the Judgment: March 7, 2025

Citation: (2025) INSC 340

Judges: Sudhanshu Dhulia, J., K. Vinod Chandran, J.

In a recent judgment, the Supreme Court of India addressed the critical issue of proving demand and acceptance of bribe in cases under the Prevention of Corruption Act, 1988. The case involved two public servants, an Enforcement Inspector and an Office Assistant, who were accused of demanding and accepting a bribe for issuing a trade license. The Supreme Court, after careful consideration of the evidence, acquitted the accused, emphasizing the importance of establishing the charges beyond reasonable doubt. The judgment was delivered by a two-judge bench comprising Justice Sudhanshu Dhulia and Justice K. Vinod Chandran.

Case Background

The case originated from a complaint lodged by PW5, an applicant for a Rajasthan Trade Authority (RTAL) license at the District Supply Office. PW5 alleged that Madan Lal, the Enforcement Inspector (Accused 2), demanded a bribe during the shop inspection to expedite the license issuance. The following day, PW5 visited the DSO and met Narendra Kumar, the Office Assistant (Accused 1), who allegedly reiterated the demand for a bribe for both accused. PW5 then reported the matter to the Anti-Corruption Bureau (ACB), leading to a trap being set.

Timeline:

Legal Framework

The case primarily revolves around the Prevention of Corruption Act, 1988. Key provisions include:

• Section 7(2) of the Prevention of Corruption Act, 1988: Deals with offences related to public servants being bribed.
• Section 13(1)(d) read with Section 13(2) of the Prevention of Corruption Act, 1988: Concerns criminal misconduct by a public servant and the punishment thereof.
• Section 20 of the Prevention of Corruption Act, 1988: Deals with presumption where public servant accepts any undue advantage.
• Section 164 of the Code of Criminal Procedure, 1973: Relates to recording of confessions and statements.

These sections form the core of the legal arguments and the court’s analysis in determining whether the accused were guilty of the alleged offenses.

Arguments

Arguments of the Accused:

• The demand for bribe was not proved due to inconsistencies in the complainant’s (PW5) statements and the initial complaint (Exhibit P-1).
• The recommendation for license issuance by the 2nd accused on the day of inspection contradicts the bribery allegation.
• The money was thrust upon the accused, and currency notes were scattered during a scuffle, making the recovery and test results unreliable.

Arguments of the State:

• The trap proceedings caught the accused red-handed.
• The complainant testified to the demand, and official witnesses confirmed the money’s receipt.
• The positive reaction of the test solution on the accused’s hands and clothes validated the transaction.
• The accused failed to rebut the presumption under Section 20 of the Prevention of Corruption Act, 1988.

Issues Framed by the Supreme Court

1. Whether the prosecution has established beyond all reasonable doubt, the demand of bribe and its acceptance, in a trap laid by the trap team of the ACB.

Treatment of the Issue by the Court: “The following table demonstrates as to how the Court decided the issues”

Authorities

The court considered the evidence presented by both sides, including the complaint, depositions of witnesses, and the trap proceedings. The judgment does not explicitly cite any specific cases or books as authorities. The primary focus was on the factual inconsistencies and the credibility of the witnesses.

Judgment

The Supreme Court allowed the appeals and acquitted the accused. The Court found that the prosecution failed to establish the demand and acceptance of a bribe beyond a reasonable doubt. The inconsistencies in the complainant’s statements, the testimony of independent witnesses, and the overall evidence created significant doubt regarding the accused’s guilt.

What weighed in the mind of the Court?:

The Court was primarily influenced by the inconsistencies in the evidence presented by the prosecution. The discrepancies in the complainant’s statements regarding the amount demanded, coupled with the independent witnesses’ accounts, raised significant doubts about the demand and acceptance of the bribe.

Key Takeaways:

• The prosecution must establish the demand and acceptance of a bribe beyond a reasonable doubt to secure a conviction under the Prevention of Corruption Act, 1988.
• Inconsistencies in the complainant’s statements and the testimony of independent witnesses can create reasonable doubt, leading to acquittal.
• The presumption under Section 20 of the Prevention of Corruption Act, 1988, does not arise if the demand and acceptance of the bribe are not proven.

Development of Law:

The ratio decidendi of the case is that the prosecution must prove the demand and acceptance of a bribe beyond a reasonable doubt for a conviction under the Prevention of Corruption Act, 1988. The judgment reinforces the importance of credible evidence and consistent testimony in corruption cases.

Conclusion:

The Supreme Court’s decision in Madan Lal vs. State of Rajasthan highlights the necessity of establishing the charges of demand and acceptance of a bribe beyond a reasonable doubt. The acquittal of the accused underscores the importance of consistent and credible evidence in corruption cases.

Category:

• Prevention of Corruption Act, 1988
  • Section 7, Prevention of Corruption Act, 1988
  • Section 13, Prevention of Corruption Act, 1988
  • Section 20, Prevention of Corruption Act, 1988
• Criminal Law
  • Bribery
  • Corruption
  • Criminal Prosecution

FAQ:

1. What is the main issue in Madan Lal vs. State of Rajasthan?

   The main issue is whether the prosecution successfully proved the demand and acceptance of a bribe by the accused beyond a reasonable doubt, as required under the Prevention of Corruption Act, 1988.

2. What was the Supreme Court’s decision?

   The Supreme Court acquitted the accused, stating that the prosecution failed to establish the demand and acceptance of a bribe beyond a reasonable doubt.

3. What factors led to the acquittal?

   Inconsistencies in the complainant’s statements, the testimony of independent witnesses, and the overall evidence created significant doubt regarding the accused’s guilt.

4. What is the significance of Section 20 of the Prevention of Corruption Act, 1988?

   Section 20 deals with the presumption that a public servant has accepted an undue advantage. However, this presumption only arises if the demand and acceptance of the bribe are proven, which was not the case in this instance.