The Supreme Court has revived a corruption case against a Karnataka Police Sub-Inspector, ruling that a public servant cannot escape scrutiny merely because an alleged bribe demand was made through subordinates or intermediaries.
A bench of Justice Sanjay Karol and Justice N. Kotiswar Singh set aside a Karnataka High Court order that had quashed the FIR at the initial stage of investigation.
Background of the Case
The case arose from a complaint filed before the Karnataka Lokayukta Police by a man whose motorcycle and mobile phone had been seized during an investigation into the alleged transportation of ration rice.
According to the complaint, after repeated visits to the police station seeking the return of his belongings, he was allegedly asked to pay money through persons connected to the police officials. The complainant alleged that a private individual initially demanded ₹50,000 on behalf of the police officer, while a police constable later allegedly sought ₹5,000, which was negotiated down to ₹3,000 along with an additional penalty amount.
Based on the complaint, the Lokayukta Police registered an FIR under Section 7(a) of the Prevention of Corruption Act, 1988.
The Karnataka High Court had quashed the FIR against PSI K. Rangayya in January 2024.
The High Court concluded that the essential ingredients of the offence were absent because there was no direct demand or acceptance of money by the officer himself. It also noted that no recovery had been made from him during the trap proceedings.
The Supreme Court disagreed with the High Court's approach and held that the court had gone beyond the limited scope of examining whether a prima facie case existed.
The Bench observed that while considering a petition to quash an FIR, courts are not expected to conduct a detailed evaluation of evidence or hold what effectively becomes a "mini-trial."
“The High Court has in effect conducted a mini-trial, which is fundamentally contrary to the settled principles governing the exercise of the quashing jurisdiction,” the Bench observed.
The Court further examined Section 7(a) of the Prevention of Corruption Act and its explanations. It emphasized that the law covers not only direct acceptance of illegal gratification but also attempts to obtain an undue advantage for another person, including through third parties.
According to the Court, the allegation that the officer told the complainant to “do something for those boys” could not be ignored at the preliminary stage. The Bench said such words, when viewed alongside the subsequent demand allegedly made by a subordinate officer, could amount to an attempt to obtain an undue advantage.
“The PC Act does not countenance any such straitjacketed formulation limiting acts of demand and acceptance only to the official himself,” the Court noted.
The respondent officer argued that the complaint was motivated by previous disputes between him and the complainant.
However, the Supreme Court held that allegations of mala fides and questions regarding the credibility of the complainant are matters to be tested during trial and cannot form the basis for quashing an FIR when the complaint otherwise discloses a cognizable offence.
Allowing the appeal filed by the State through the Lokayukta Police, the Supreme Court set aside the Karnataka High Court's order and restored the FIR and all related proceedings against the police officer.
The Court clarified that its observations were limited to determining whether a prima facie case existed and would not affect the trial court's independent assessment of guilt or innocence during the trial.
Case Details:
Case Title: The State by Lokayuktha Police v. Sri K. Rangayya & Anr.
Case Number: Criminal Appeal arising out of SLP (Criminal) No. 5245 of 2025
Judges: Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh
Decision Date: 26 May 2026
