In a significant verdict that clarifies the legal standards for proving corruption, the Rajasthan High Court has acquitted three Railway Protection Force (RPF) personnel, setting aside their conviction and one-year sentence in a 16-year-old bribery case. The court ruled that a conviction cannot be based solely on a trap operation and laid down essential ingredients the prosecution must prove.
The Court's Landmark Ruling on Bribery Convictions
Justice Anand Sharma of the Rajasthan High Court delivered the judgment on Friday, overturning the 2023 decision of a special court in Jaipur. The court established a crucial legal principle: a bribery conviction cannot rest solely on the recovery of money during a trap operation. For a successful prosecution, the state must prove three elements beyond reasonable doubt.
The prosecution must conclusively establish:
- The demand of a bribe by the accused.
- The acceptance of the bribe.
- The existence of pending official work related to the accused.
The court found that the prosecution in this case failed to meet this stringent burden of proof, particularly regarding the demand and the pending work.
Case Details: A 16-Year Legal Battle
The case dates back to 2007. The complainant, Chiranji Lal, approached the Anti-Corruption Bureau (ACB) with an allegation that RPF officials posted at Ringas in Sikar district had demanded Rs 5,000 from him. The money was allegedly to remove his name and provide relief to his brother in a case registered under the Railway Act. According to the complaint, Rs 2,000 had already been paid, and the remaining Rs 3,000 was to be paid later.
Based on this, the ACB laid a trap on July 26, 2007. During the operation, the bribe amount was recovered from constable Sanwarmal Meena. After a protracted trial spanning nearly 16 years, the special court for ACB cases in Jaipur convicted all three accused in 2023. The convicted individuals were the then RPF Station House Officer Kailash Chand Saini, duty officer/constable Jagveer Singh, and constable Sanwarmal Meena. Each was sentenced to one year of rigorous imprisonment.
Defense Argument and Grounds for Acquittal
Appealing the conviction in the High Court, the accused were represented by senior counsel Madhav Mitra, assisted by Jaya Mitra. The defense successfully argued that the prosecution's case was fundamentally flawed.
Madhav Mitra argued, "We maintained that the prosecution failed to prove the fundamental requirement of demand, which is the most crucial element in corruption cases. There was no audio or video recording of the alleged demand made on July 13, 2007, nor were there any independent witnesses to corroborate the complainant's version, whose testimony itself contained contradictions."
Furthermore, the defense stressed a critical missing link: there was no pending official work. The Railway Act case against the complainant and his brother, which formed the basis for the alleged bribe demand, did not exist or was not substantiated. The High Court concurred, observing that the prosecution failed to produce any material evidence to prove either the demand for the bribe or its acceptance by the appellants.
The court held that without proof of demand and pending work, the mere recovery of money in a trap was insufficient to sustain a conviction. This judgment underscores the importance of comprehensive evidence in corruption cases and prevents convictions based merely on trap recoveries without establishing the core illegal agreement.
