Legal Review and Analysis of P Somaraju vs State of Andhra Pradesh 2025 INSC 1263

1. Heading of the Judgment

Case Name: P. Somaraju vs. State of Andhra Pradesh
Citation: 2025 INSC 1263
Court: Supreme Court of India
Judges: Justice Prashant Kumar Mishra and Justice Joymalya Bagchi
Date: October 28, 2025

2. Related Laws and Sections

The judgment primarily interprets and applies the following provisions of the Prevention of Corruption Act, 1988 (PC Act):

• Section 7: Offence relating to public servant being bribed.

• Section 13(1)(d) read with Section 13(2): Criminal misconduct by a public servant and its punishment.

• Section 20: Presumption where public servant accepts any undue advantage.

3. Basic Judgment Details

This is a Criminal Appeal (No. 1770 of 2014) filed before the Supreme Court of India. The Appellant is P. Somaraju, a former public servant who was an Assistant Commissioner of Labour. The Respondent is the State of Andhra Pradesh. The appeal challenged the judgment of the Andhra Pradesh High Court dated July 8, 2011, which had reversed the Trial Court's order of acquittal and convicted the appellant under the PC Act. The case originated from a trap conducted by the Anti-Corruption Bureau (ACB) on September 26, 1997, where the appellant was alleged to have accepted a bribe of ₹3,000 for renewing labour licenses.

4. Core Principle of the Judgment: Analysis of Reversal of Acquittal in Corruption Case

The Central Issue

The pivotal legal question before the Supreme Court was: Did the High Court err in law by reversing the Trial Court's order of acquittal, despite the existence of a reasonable view of the evidence supporting the appellant's innocence, and by failing to adhere to the well-settled principles governing such reversals?

The Supreme Court's Analysis and Reasoning

The Supreme Court conducted a thorough review of the evidence and the reasoning of both the Trial Court and the High Court. Its analysis focused on the following critical aspects:

• The Sanctity of Acquittal and the Appellate Court's Limited Power: The Court began by reiterating the seminal principles governing appeals against acquittal, as laid down in Chandrappa & Ors. vs. State of Karnataka (2007) 4 SCC 415. It emphasized that an appellate court has the power to review evidence but must remember the "double presumption of innocence" in favour of the accused: first, the presumption of innocence until proven guilty, and second, the presumption reinforced by an acquittal. The Court stressed that if two reasonable conclusions are possible, the appellate court must not disturb the acquittal. Interference is warranted only if the Trial Court's view is "perverse, based on misreading or ignoring material evidence, or results in manifest miscarriage of justice."

• The Primacy of Proving Demand and Acceptance: The judgment underscored that for an offence under the PC Act, the proof of demand and voluntary acceptance of illegal gratification is the foundation of the case. Relying on Rajesh Gupta vs. State through CBI (2022 INSC 359), the Court held that the mere recovery of tainted money is not sufficient to convict an accused. The statutory presumption under Section 20 of the PC Act arises only after these foundational facts are firmly established beyond reasonable doubt.

• Scrutiny of Prosecution's Flaws and Contradictions: The Supreme Court identified multiple material infirmities in the prosecution's case that the High Court had either ignored or incorrectly dismissed:
  Failure of the Trap Procedure: The independent witness (PW-2, Rajender), who was instructed by the DSP to accompany the complainant into the appellant's office to witness the transaction, was deliberately asked to wait outside by the complainant. This critical lapse meant there was no independent corroboration for the alleged demand and acceptance inside the room.
  Inconsistencies in the Complaint: The complaint (Ex. P1) was written on the morning of September 25, 1997, yet it detailed a bribe demand that allegedly occurred that same evening. The complaint also referred to the accused by an incorrect name ("Rama Raju").
  Negative Phenolphthalein Test: The sodium carbonate hand-wash test on the appellant yielded a negative result, indicating he had not handled the tainted notes. The Supreme Court criticized the High Court for speculating that this was a "method adopted by clever public servants," stating that such "strong suspicion cannot take the place of proof."
  Hostile Witness and Unexplained Omissions: The office attendant (PW-4, Abbas) turned hostile and alleged coercion by the ACB. The other mediator was not examined. The DSP admitted that other office staff and visitors were not questioned.

• Credibility of the Defence Version: The Court found that the defence presented a reasonable and probable version of events. The appellant claimed he had briefly left his office to use the toilet, and the complainant, taking advantage of his absence, planted the money in the table drawer. This version was corroborated by two defence witnesses (DW-1 and DW-2), whose testimonies were consistent, natural, and could not be dismissed merely because they had official dealings with the appellant.

• High Court's Substitution of View Over Reasonable Doubt: The Supreme Court held that the High Court erred by not demonstrating that the Trial Court's view was perverse. Instead, the High Court merely substituted its own inferences for those of the Trial Court without adequately addressing the numerous lacunae and contradictions in the prosecution's evidence. The Supreme Court concluded that the Trial Court's acquittal was a reasonable one based on the evidence, and the High Court's reversal was unsustainable in law.

5. Final Outcome of the Judgment

The Supreme Court allowed the appeal filed by P. Somaraju.

• The impugned judgment of the Andhra Pradesh High Court, which had convicted the appellant, was set aside.

• The order of acquittal dated November 28, 2003, passed by the Trial Court was restored.

• The appellant's bail bonds were discharged.

The Supreme Court authoritatively held that the High Court had erroneously reversed a well-reasoned acquittal by ignoring settled legal principles, material contradictions in the prosecution's case, and the defence's reasonable explanation, thereby restoring the acquittal of the appellant.

6. MCQs Based on the Judgment

Question 1: In the case of P. Somaraju vs. State of A.P. (2025 INSC 1263), the Supreme Court restored the acquittal primarily because?
a) The appellant had an impeccable service record.
b) The sanction for prosecution under the PC Act was invalid.
c) The High Court failed to adhere to the legal principles governing the reversal of an acquittal and the prosecution did not prove demand and acceptance of bribe beyond reasonable doubt.
d) The amount of bribe involved was considered too trivial for a conviction.

Question 2: According to the Supreme Court's judgment, when can the statutory presumption under Section 20 of the Prevention of Corruption Act, 1988, be invoked against an accused?
a) As soon as the tainted money is recovered from the possession of the accused.
b) Only after the prosecution successfully proves the foundational facts of demand and acceptance of illegal gratification beyond reasonable doubt.
c) Automatically in every case where a public servant is caught in a trap.
d) When the accused fails to explain the source of the money recovered.