Below are judgment-wise case notes on the Prevention of Corruption Act, 1988, curated exclusively for Judicial Service Exams.
Each note is framed in the exact style useful for Mains answers, Prelims MCQs, and interviews.
📚 Judgment-Wise Case Notes
Prevention of Corruption Act, 1988
1. Subramanian Swamy v. Manmohan Singh
(2012) 3 SCC 64
Issue
Whether delay in granting sanction for prosecution of a public servant is permissible?
Held
- Sanction must be granted within a reasonable time
- Normally within 3 months, extendable to 4 months with reasons
- Delay defeats the object of the Act
Ratio Decidendi
Sanction is meant to facilitate prosecution, not to protect corruption.
Exam Use
- Quoted in questions on Section 19 – Sanction
- Useful for answer: “Delay in sanction cannot be used as a shield”
2. P. Satyanarayana Murthy v. State of A.P.
(2015) 10 SCC 152
Issue
Is mere recovery of bribe money sufficient for conviction?
Held
❌ No conviction without proof of demand
Ratio
- Demand of bribe is sine qua non
- Recovery is only corroborative
Exam Use
- Most important case for Section 7
- Appears frequently in Prelims
3. B. Jayaraj v. State of A.P.
(2014) 13 SCC 55
Issue
Whether presumption under Section 20 applies without proof of demand?
Held
- Presumption arises only after demand and acceptance are proved
Key Principle
Section 20 cannot be invoked mechanically
Exam Use
- Link with burden of proof
- Good authority for acquittal reasoning
4. Neeraj Dutta v. State (NCT of Delhi)
(2023) 4 SCC 731 🔥 (VERY IMPORTANT – Latest)
Issue
Can demand be proved by circumstantial evidence?
Held
✔ Yes
Ratio
- Demand need not always be proved by direct evidence
- Can be inferred from:
- Conduct of accused
- Surrounding circumstances
- Electronic evidence
Exam Use
- Modern interpretation of “demand”
- Very likely Mains & Interview question
5. State of Punjab v. Madan Mohan Lal Verma
(2013) 14 SCC 153
Issue
Reliability of trap witnesses
Held
- Trap witnesses are not accomplices
- Their evidence cannot be discarded merely because they are interested
Principle
Evidence must be carefully scrutinized, not rejected outright
6. Krishan Chander v. State of Delhi
(2016) 3 SCC 108
Issue
Effect of defective sanction
Held
- Defective sanction does not vitiate trial
- Accused must show failure of justice
Exam Use
- Strong authority for procedural irregularity
7. N. Vijayakumar v. State of Tamil Nadu
(2021) 3 SCC 687
Issue
Conviction based only on recovery and phenolphthalein test
Held
❌ Conviction unsustainable without proof of demand
Key Takeaway
Chemical test ≠ proof of corruption
8. M. Narasinga Rao v. State of A.P.
(2001) 1 SCC 691
Issue
Nature of presumption under Section 20
Held
- Presumption is mandatory
- Rebuttable on preponderance of probability
Exam Use
- Excellent for explaining standard of rebuttal
9. V. Sejappa v. State
(2016) 12 SCC 150
Issue
Whether shadow witness turning hostile destroys prosecution case?
Held
- Not fatal if demand is otherwise proved
- Court can rely on other evidence
10. C.M. Girish Babu v. CBI
(2009) 3 SCC 779
Issue
Defence of money taken as loan
Held
- Accused must establish defence with probable explanation
- Mere assertion is insufficient
11. State of A.P. v. P. Venkateshwarlu
(2015) 7 SCC 283
Issue
Bribe paid under compulsion
Held
- Bribe giver is not an accomplice
- Covered under protection clause (now Section 8)
12. Prakash Singh Badal v. State of Punjab
(2007) 1 SCC 1
Issue
Who is a public servant?
Held
- Definition under Section 2(c) is very wide
- Political position does not grant immunity
Exam Use
- Perfect for definition-based questions
13. R. Venkatkrishnan v. CBI
(2009) 11 SCC 737
Issue
Proof of criminal misconduct
Held
- Prosecution must establish dishonest intention
- Mere procedural irregularity is insufficient
14. State v. C. Uma Maheswara Rao
(2004) 4 SCC 399
Issue
Whether demand can be presumed?
Held
❌ Demand must be affirmatively proved
One-Line Golden Rules (Highly Scorable)
- Demand is the soul of corruption offence
- Recovery follows demand, not vice-versa
- Presumption is rebuttable, not absolute
- Sanction is a sword, not a shield
- Trap witnesses ≠ accomplices
📌 How to Use These in Exams
Prelims
- Focus on ratios & keywords
- Match case → principle
Mains
- Start with:
“In P. Satyanarayana Murthy, the Supreme Court held…” - Apply facts → conclude
Interview
- Quote Neeraj Dutta (2023) confidently