Supreme Court Overturns Conviction in Bribery Case, Citing Doubtful Evidence.


09 May 2025 Corruption >> Criminal Law   |   Criminal Trial >> Criminal Law   |   Evidence >> Criminal Law  

The Supreme Court of India has allowed an appeal filed by a former Revenue Inspector, setting aside his conviction and sentence under the Prevention of Corruption Act, 1988. The judgment of Paritala Sudhakar v/s State of Telangana, delivered on 09.05.2025, found material contradictions in the prosecution's evidence, leading the Court to conclude that the guilt of the appellant had not been proven beyond reasonable doubt.

The case originated from a complaint filed in 2003 by a person (PW1) seeking compensation for trees allegedly damaged by drought. The appellant, then working at the Mandal Revenue Office (MRO) in Gundala Mandal, was tasked with conducting an inquiry. It was alleged that the appellant demanded a bribe of Rs. 2,000/- from PW1 for this purpose. Following a complaint to the Anti-Corruption Bureau, a trap was laid, and while the bribe money was recovered from a bag on the appellant's motorcycle, tests on his hands for chemical residue proved negative.

 
 

The Trial Court convicted the appellant in 2008, a decision that was subsequently upheld by the High Court of Telangana in March 2024. Aggrieved by this, the appellant approached the Supreme Court.

The Supreme Court, after examining the evidence and the judgments of the lower courts, noted "material contradictions" in the testimonies of the witnesses. The Court highlighted inconsistencies in PW1's account of where and how the bribe money was placed on the appellant's motorcycle. Initially, PW1 stated he placed the money while the appellant was inside the house, but later claimed the appellant was present. This discrepancy was crucial, especially since the trap party members, positioned nearby, did not corroborate the latter version.

Furthermore, the Court took note of the testimony of PW3, who mentioned a prior altercation between the appellant and PW1, suggesting a potential motive for a false accusation. While the High Court had dismissed this aspect without explanation, the Supreme Court found it pertinent.

Adding to the doubts, the complainant's wife (DW1) testified that she was unaware of any demand for money made by the appellant while he was at their house.

The Court observed that while minor discrepancies in witness testimonies are common, the inconsistencies in this case were significant enough to cast serious doubt on the prosecution's version of events. Quoting precedents, the Court reiterated that the accused is presumed innocent until proven guilty beyond a reasonable doubt and that the prosecution must present trustworthy evidence to secure a conviction.

Regarding the presumption under Section 20 of the Prevention of Corruption Act, which the prosecution had invoked due to the recovery of money, the Supreme Court clarified that this presumption only applies when the demand for the bribe is proven. In this case, the Court found the element of demand itself to be questionable.

In light of these observations, the Supreme Court allowed the appeal, set aside the conviction and sentence, and extended the benefit of doubt to the appellant. The judgments of the Trial Court and the High Court were quashed. The Court also directed the refund of any fine deposited by the appellant.

This judgment underscores the importance of consistent and credible evidence in corruption cases and reiterates the fundamental principle of criminal jurisprudence that the burden of proving guilt beyond a reasonable doubt rests with the prosecution.


Section 7, Prevention of Corruption Act - 1988  

Section 13, Prevention of Corruption Act - 1988  

Section 20, Prevention of Corruption Act - 1988  

Prevention of Corruption Act, 1988