The Supreme Court has acquitted former Railway Protection Force (RPF) Divisional Security Commissioner Bharat Raj Meena in two corruption prosecutions arising from a 2005 CBI investigation into alleged payments for transfers and postings. A Bench of Justice Dipankar Datta and Justice N. Kotiswar Singh held that the prosecution evidence left reasonable doubt about whether Meena had demanded or accepted illegal gratification through intermediaries.
The judgment was delivered on September 16, 2026, in Criminal Appeal Nos. 4732 and 4733 of 2024.
Background
The CBI case originated from FIR No. RC19(A)/2005/KER/CBI registered on August 4, 2005. At the relevant time, Meena was serving as Divisional Security Commissioner, RPF, Palakkad.
The prosecution alleged that money was collected from RPF personnel seeking favourable transfers, postings and other service-related benefits through subordinate officials, particularly Anantha Narayanan and Abdul Gafoor. The investigation referred to 12 alleged transactions involving amounts between ₹5,000 and ₹13,000.
In the first case, C.C. No. 2 of 2014, the prosecution relied on a trap involving complainant P.P. Nandakumar. Anantha Narayanan was caught with ₹5,000 allegedly paid on Meena's behalf. Both the trial court and the Kerala High Court had convicted Meena in this case.
The second appeal concerned C.C. No. 3 of 2015, where the surviving allegation related to N.P. Gopi Kumar. The High Court had affirmed Meena's conviction concerning that transaction.
The Supreme Court emphasised that merely showing that money changed hands is not enough in a prosecution under the Prevention of Corruption Act. The prosecution must establish the necessary link between the accused and the alleged demand and acceptance.
The Court also considered the evidence of Anantha Narayanan and Abdul Gafoor, who were originally accused in the case but were later granted pardon and examined as approvers. It noted that such testimony requires careful scrutiny and material corroboration connecting the accused with the alleged transaction.
In the Nandakumar transaction, the Court found significant gaps. Although the money was recovered from Anantha Narayanan, it was not recovered from Meena. The Court also noted that the prosecution's own witnesses differed about what happened when Nandakumar met Meena and subsequently handed over the money to the intermediary.
The Court observed that the evidence established, at its highest, that money reached the intermediary, but did not reliably establish that Meena ultimately received or obtained it.
The Court further criticised the decision to end the trap after recovering the money from the intermediary instead of allowing the alleged chain of payment to continue. It said this investigation gap created reasonable doubt about the prosecution's case.
The Court separately examined the allegation involving Gopi Kumar. According to the prosecution, Gopi Kumar met Meena at his residence and subsequently paid ₹3,000 to Abdul Gafoor, who allegedly handed the money to Meena.
However, the Court found that the Inspector who allegedly contacted Gopi Kumar at Meena's instance was not examined. There were also no call records or official movement records placing Meena at his residence at the relevant time.
The Court also relied on Meena's contemporaneous diary, which recorded that he was away from Palakkad on July 30, 2005, the only date appearing in the record for the alleged meeting. No satisfactory explanation was provided to reconcile the diary entry with the prosecution version.
The Court stated that the foundational facts required for drawing the statutory presumption had not been established with the necessary quality of evidence.
Holding that the prosecution had failed to prove the charges beyond reasonable doubt, the Supreme Court allowed both appeals.
“Crl. Appeal No. 4733 of 2024 … is allowed, and the appellant is acquitted of all charges therein.”
The Court similarly allowed Criminal Appeal No. 4732 of 2024 and acquitted Meena of all charges in that case.
His bail bonds were discharged, and any fine deposited was ordered to be refunded.
