Source: Supreme Court 

Why in News? 

Recently, the bench of Justice Sudhanshu Dhulia and Justice K Vinod Chandran has held that a presumption under Section 20 of the Prevention of Corruption Act, 1988 (“PC Act”) would not arise against the accused unless the factum of demand and acceptance of bribe is established by the prosecution. 

• The Supreme Court  held in the matter of Madan Lal v. State of Rajasthan (2025). 

What was the Background of the Madan Lal v. State of Rajasthan Case? 

• This case involves two accused persons - Madan Lal (2nd accused), an Enforcement Inspector, and Narendra Kumar (1st accused), an Office Assistant, both working in the Supply Department. 
• They were charged under PC Act for allegedly demanding and accepting a bribe. 
• The complainant had applied for a Rajasthan Trade Authority License (RTAL) at the District Supply Office to sell food grains and edible oils. 
• The complainant alleged that during the inspection of his shop, Madan Lal demanded a bribe to expedite the issuance of his license. 
• The complainant visited the District Supply Office at Sri Ganganagar the next day where he met both accused persons, and allegedly Narendra Kumar demanded a bribe on behalf of both of them. 
• The complainant had already paid the legitimate license fee of Rs. 1000. 
• Distressed by the bribe demand, the complainant approached the Anti-Corruption Bureau (ACB). 
• The ACB set up a trap operation the very next day based on the complaint. 
• According to the complainant's original statement to the ACB, the amount demanded was Rs. 400 (Rs. 300 for Narendra Kumar and Rs. 200 for Madan Lal, later negotiated down to Rs. 400 total). 
• The trap involved marked currency notes, and a test solution designed to detect traces of the solution on hands and clothing upon contact with the currency. 
• The prosecution's case was built upon both the alleged demand by the accused and the subsequent trap proceedings conducted by the ACB. 
• Both accused persons were initially convicted by the Trial Court, which was upheld by the High Court, leading to this appeal before the Supreme Court. 

What were the Court’s Observations? 

• The Supreme Court observed that: 
  • The Supreme Court noted "glaring inconsistencies" in the evidence regarding the amount of money demanded as a bribe. 
  • The Court highlighted that during cross-examination, the complainant admitted he couldn't remember the exact amount demanded by the 2nd accused, contradicting his earlier complaint. 
  • Regarding the trap, the Court observed that independent witnesses didn't actually witness the physical transaction of the bribe, having entered the scene only after the complainant's signal. 
  • The Court noted discrepancies in testimony: some witnesses stated currency notes were found scattered on the floor, while trap officers claimed the money was recovered from the accused persons' trouser pockets. 
  • The Supreme Court found that the testimonies of the independent witnesses contradicted the prosecution's version of events. 
  • The Court concluded that these contradictions created "reasonable doubt" about whether there was actual acceptance of bribe amounts by both accused. 
  • The Supreme Court held that the prosecution failed to establish beyond reasonable doubt both the demand for a bribe and its acceptance. 
  • The Court ruled that without proof of demand and acceptance, the presumption under Section 20 of PCA could not be applied. 
  • Based on these observations, the Supreme Court set aside the conviction and sentences of both accused, acquitting them of all charges. 

What is Section 20 of PC Act? 

• Section 20: Presumption where public servant accepts any undue advantage 
  • In any trial concerning offences punishable under section 7 or section 11, if it is established that a public servant has accepted, obtained, or attempted to obtain any undue advantage, a legal presumption arises. 
  • This presumption states that the public servant is deemed to have accepted or attempted to obtain that undue advantage unless proven otherwise. 
  • This provision aims to deter corrupt practices among public officials by placing the burden of proof on the accused to demonstrate their innocence.