Introduction In a significant ruling, the Supreme Court of India in Madan Lal v. State of Rajasthan (2025 INSC 340) overturned the conviction of two government officials accused of bribery under the Prevention of Corruption Act, 1988. The judgment underscores the necessity of proving both demand and acceptance of bribe money beyond a reasonable doubt.
Case Background The case originated from a complaint lodged with the Anti-Corruption Bureau (ACB) by a businessman who had applied for a Rajasthan Trade Authority License (RTAL) at the District Supply Office. He alleged that the Enforcement Inspector, Madan Lal, and Office Assistant, Narendra Kumar, demanded a bribe for processing his application.
A trap was laid by the ACB, leading to the arrest of the accused. The Trial Court convicted both officials under Section 13(1)(d) read with Section 13(2) and Section 7(2) of the Prevention of Corruption Act, sentencing them to rigorous imprisonment and fines. The High Court upheld the conviction, prompting an appeal to the Supreme Court.
Supreme Court’s Findings Upon reviewing the evidence, the Supreme Court found inconsistencies in the prosecution’s case. The key observations included:
- Inconsistent Testimony of the Complainant: The complainant’s statements regarding the amount of the bribe varied between his complaint to the ACB and his deposition in court.
- Unreliable Independent Witnesses: The two independent witnesses, who were government employees, turned hostile and did not confirm witnessing the alleged bribe transaction.
- Unclear Trap Proceedings: The court noted that some currency notes were found scattered on the floor, and no witness could conclusively establish that the accused had voluntarily accepted the bribe.
- Lack of Corroboration: The prosecution failed to prove that the accused had demanded and accepted the bribe beyond a reasonable doubt.
Legal Implications The judgment reaffirmed that under Section 20 of the Prevention of Corruption Act, the presumption of guilt arises only when demand and acceptance are unequivocally established. The Supreme Court emphasized that mere possession of tainted currency is insufficient for conviction without substantive proof of demand.
Conclusion The acquittal of the accused in Madan Lal v. State of Rajasthan highlights the importance of concrete evidence in corruption cases. The ruling serves as a reminder that courts must scrutinize prosecution claims rigorously to prevent wrongful convictions based on weak or contradictory evidence.
References:
- Madan Lal v. State of Rajasthan, 2025 INSC 340
- Prevention of Corruption Act, 1988
- Code of Criminal Procedure, 1973