In Brief
The Supreme Court held that Managing Directors and Executive Directors of Global Trust Bank (a private bank licensed by the Reserve Bank of India) are public servants for purposes of the Prevention of Corruption Act, 1988. Although the Banking Regulation Act's deeming provision (Section 46A) originally referenced now-repealed IPC sections, the Court interpreted this as a clear legislative omission capable of judicial correction given Parliament's explicit intent to expand anti-corruption coverage. The Court applied purposive interpretation to harmonize the statutory scheme, ruling that the respondents could be prosecuted under the Prevention of Corruption Act despite the bank being private, and set aside the lower courts' orders declining cognizance.
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