Supreme Court Restores Acquittal in Corruption Case: Criminal Process Strength Lies in Restraint as Much as Scrutiny

The Supreme Court emphasized on Tuesday that the strength of the criminal process lies in restraint as much as in scrutiny, while restoring the acquittal of a man in a 1997 corruption case.

The top court set aside a July 2011 order of the Andhra Pradesh High Court, which had reversed a trial court's acquittal in Hyderabad and convicted the man for alleged offences under the Prevention of Corruption Act.

The high court had sentenced the man, who served as an Assistant Commissioner of Labour from January to September 1996, to undergo one year's imprisonment.

Addressing his plea challenging the high court's verdict, a bench comprising Justices Prashant Kumar Mishra and Joymalya Bagchi stated that the trial court's view was both reasonable and firmly rooted in the evidence on record.

The bench observed that the high court failed to engage with the trial court's detailed reasoning and instead substituted its own inferences without addressing the "evidentiary gaps."

"The strength of the criminal process lies in restraint as much as in scrutiny. The appellant's acquittal, having stood on reasonable grounds, deserves to stand restored," the bench declared, while reinstating the trial court's acquittal order.

The prosecution had alleged that the appellant demanded Rs 9,000 as bribe from the complainant for renewing contract labour licenses.

The Supreme Court noted that the trial court had acquitted the appellant in November 2003, ruling that the prosecution failed to prove demand and acceptance of bribe beyond reasonable doubt.

Aggrieved by the trial court's decision, the state approached the high court, which subsequently convicted the appellant.

Referring to the evidence, the top court emphasized that suspicion, however strong, cannot replace proof.

"In the instant case, too, the sole basis of the prosecution to prove demand and acceptance is the narration of the complainant, a close scrutiny of which reveals serious infirmities," the bench stated.

In allowing the appeal, the court noted that contract labour regulation is "necessarily precarious," and an officer cannot be faulted for requiring documentary proof of compliance, especially when the request is recorded in writing.