State By Lokayuktha Police Vs K. Rangayya & Anr. (Supreme Court of India)
SC Revives FIR: “Do Something for These Boys” Viewed as Prima Facie Bribe Solicitation; SC: Bribe Demand Need Not Be Direct – Asking to “Take Care of My Boys” Can Attract PC Act
The Supreme Court, in State by Lokayuktha Police v. Sri K. Rangayya & Anr., restored a corruption FIR against a Karnataka Police Sub-Inspector and held that, at the stage of quashing, courts cannot conduct a mini-trial by examining the strength of evidence or the outcome of trap proceedings.
The allegation was that the PSI, after arranging release of the complainant’s seized vehicle, told him to “do something for these boys,” following which a subordinate constable allegedly demanded ₹5,000 (later reduced to ₹3,000). The Karnataka High Court had quashed the FIR on the ground that there was no direct demand or acceptance of bribe by the PSI himself.
Reversing the High Court, the Supreme Court emphasized the expanded scope of Section 7(a) of the Prevention of Corruption Act, 1988, particularly Explanation 2, which makes it clear that an offence is made out even where a public servant attempts to obtain an undue advantage for another person or does so through a third party or subordinate. The Court observed that corruption law cannot be defeated by senior officials operating through intermediaries while maintaining personal distance from the actual collection of money.
