Case Title: State Of Lokayuktha Police, Davanagere v. C B Nagaraj (Neutral Citation: 2025 INSC 736)
The Supreme Court held that just because money changed hands, it cannot be ipso facto presumed that the same was pursuant to a demand for illegal gratification. The Court dismissed an Appeal filed by the State of Lokayuktha Police, Davanagere, thereby upholding the Order of the Karnataka High Court that had set aside the conviction of an Extension Officer (Respondent) in the office of the Taluka Panchayath, who had been found guilty by the Special Court under Sections 7, 13(1)(d) and 13(2) of the Prevention of Corruption Act, 1988 (PC Act).
The Bench of Justice Pankaj Mithal and Justice Ahsanuddin Amanullah held, “The observation of the High Court to this extent is correct that just because money changed hands, in cases like the present, it cannot be ipso facto presumed that the same was pursuant to a demand, for the law requires that for conviction under the Act, an entire chain – beginning from demand, acceptance, and recovery has to be completed. In the case at hand, when the initial demand itself is suspicious, even if the two other components – of payment and recovery can be held to have been proved, the chain would not be complete.”
