The Supreme Court reiterated the established principle that an appellate court should not reverse an acquittal unless the trial court’s view is perverse or based on a manifest misreading of evidence. The prosecution must prove the foundational facts of demand and acceptance of a bribe beyond reasonable doubt, and mere recovery of money is insufficient for conviction under the Prevention of Corruption Act.
Facts Of The Case:
The appellant, an Assistant Commissioner of Labour, was accused of demanding a bribe of ₹9,000 from a labour contractor for renewing three licences. The prosecution alleged that a partial payment of ₹3,000 was made on 25.09.1997, with the balance demanded the next day. The complainant reported this to the Anti-Corruption Bureau (ACB), which laid a trap on 26.09.1997. According to the prosecution, the complainant entered the appellant’s office alone and, upon a repeated demand, placed tainted currency notes totalling ₹3,000 in a table drawer as instructed. The appellant then allegedly signed the licences. The trap party recovered the money, and a swab of the drawer tested positive for phenolphthalein. However, the appellant’s hand-wash test was negative. The Trial Court acquitted the appellant, citing material inconsistencies in the complaint, the lack of independent corroboration for the demand, and serious procedural lapses, including the key mediator being kept outside the room during the alleged transaction. The High Court reversed this acquittal and convicted the appellant. The Supreme Court ultimately set aside the High Court’s judgment and restored the acquittal.
Procedural History:
The procedural history of this case commenced with the filing of a chargesheet on 16.08.1999 after obtaining sanction for prosecution. The Trial Court (Principal Special Judge for SPE & ACB Cases, Hyderabad) framed charges on 11.07.2000, but after trial, acquitted the appellant on 28.11.2003, holding that the prosecution failed to prove the demand and acceptance of a bribe beyond reasonable doubt. The State of Andhra Pradesh appealed this acquittal to the High Court, which reversed the Trial Court’s order and convicted the appellant vide judgment dated 08.07.2011. The appellant then appealed to the Supreme Court, which, in its judgment dated 28.10.2025, allowed the appeal, set aside the High Court’s conviction, and restored the Trial Court’s order of acquittal.
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