The Supreme Court held that exoneration in departmental proceedings does not bar continuation of criminal prosecution, as the standards of proof and purpose differ. However, it remanded the case to the trial court to determine the validity of the prosecution sanction, emphasizing that sanction must be granted by the authority competent to remove the public servant from office.
Facts Of The Case:
The appellant, T. Manjunath, a Senior Inspector of Motor Vehicles in Bengaluru, was accused of demanding and accepting a bribe of ₹15,000 through an intermediary. Following a trap by the Lokayukta, a criminal case was registered under the Prevention of Corruption Act, 1988. The Transport Commissioner granted sanction for prosecution, and a chargesheet was filed. The appellant sought discharge, challenging the sanction’s validity, arguing that as a State Government appointee, only the State could sanction his prosecution. He also cited his exoneration in parallel departmental proceedings based on the same evidence, where key witnesses turned hostile. The trial court accepted the sanction argument and discharged him. The High Court reversed this, upholding the sanction’s validity based on a government notification. Before the Supreme Court, the appellant contended that the departmental exoneration should quash the criminal case and reiterated the sanction issue. The State argued that the two proceedings are independent and that a conviction could still be based on the trap officer’s testimony.
Procedural History:
The procedural history of this case began with the trial court discharging the accused-appellant, T. Manjunath, primarily on the ground that the sanction for prosecution granted by the Transport Commissioner was invalid, as he was not the competent authority to remove the appellant from service. The trial court allowed the discharge application but granted liberty to the prosecution to file a fresh chargesheet after obtaining proper sanction. Both the State and the accused filed revision petitions against this order before the High Court of Karnataka. The High Court reversed the trial court’s decision, holding that the sanction was validly accorded by the competent authority and directed the trial to proceed. Aggrieved by this reversal, the accused-appellant approached the Supreme Court by way of special leave, leading to the present appeal and the final judgment.
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Court Observation:
The Supreme Court made two pivotal observations. First, it categorically held that exoneration in departmental proceedings, based on a lower standard of proof, does not automatically warrant the quashing of criminal prosecution, especially in trap cases, as the nature, scope, and standard of proof in the two forums are fundamentally different. Second, on the issue of sanction under the Prevention of Corruption Act, the Court emphasized that the authority competent to grant sanction must be the one empowered to remove the public servant from office. Finding a factual dispute regarding the appellant’s actual appointing authority, the Court set aside the High Court’s finding on sanction and remanded the limited question of the sanction’s validity to the trial court for fresh determination based on original appointment records.
Final Decision & Judgement:
The Supreme Court partly allowed the appeal. It rejected the appellant’s plea for discharge based on his departmental exoneration, ruling that criminal proceedings must continue independently. However, the Court set aside the High Court’s finding on the validity of the prosecution sanction. It remanded the case to the trial court for a fresh determination on the limited issue of identifying the competent appointing authority and, consequently, whether the sanction was granted by the appropriate authority. The trial court was directed to examine original records and decide accordingly; if the sanction is found valid, the trial shall proceed, otherwise, the chargesheet must be returned for fresh sanction.
Case Details:
Case Title: T. Manjunath vs. The State of Karnataka & Anr. Citation: 2025 INSC 1356 Criminal Appeal No.: (Arising out of SLP(Crl.) No(s). 11160-11161 of 2024) Date of Judgement: November 10, 2025 Judges/Justice Name: Justice Vikram Nath & Justice Sandeep Mehta
Download The Judgement Here