Supreme Court: handing bribe to intermediary alone does not prove public servant's guilt

The core issue is whether the handover of bribe money to an intermediary is sufficient to prove the guilt of the public servant under the Prevention of Corruption Act.

Who it concerns: Appellant: Bharat Raj Meena; Respondent: Central Bureau of Investigation (CBI); Bench: Justice Nongmeikapam Kotiswar Singh.

What the court decided

• The Court heard Criminal Appeal No. 4732 of 2024 and Criminal Appeal No. 4733 of 2024 together.
• The appeals arise from convictions in C.C. No. 2 of 2014 and C.C. No. 3 of 2015 by the Special Judge (SPE/CBI)-III, Ernakulam.
• The convictions were affirmed by the High Court of Kerala in Criminal Appeal No. 591 of 2016 and Criminal Appeal No. 587 of 2016.
• The Court is examining the sufficiency of evidence regarding demand and acceptance of illegal gratification through intermediaries Anantha Narayanan and Abdul Gafoor.
• The Court is assessing the evidentiary value of approver testimony and the invocation of the statutory presumption under Section 20 of the Prevention of Corruption Act, 1988.

Also in the document

• The judgment is marked as 'REPORTABLE' and cited as 2026 INSC 999.
• The prosecution alleged twelve separate instances of illegal gratification ranging from ₹5,000 to ₹13,000 collected between April 2005 and August 2005.
• The intermediaries, Anantha Narayanan and Abdul Gafoor, were granted pardon under Section 306 Cr.P.C. and testified as approvers.
• In C.C. No. 3 of 2015, the High Court upheld the conviction only for the transaction involving N.P. Gopi Kumar, while the conviction for C.K. Aravindan was not affirmed by the High Court.