In Brief
P. Sarangapani, a Sub Registrar, was convicted of accepting illegal gratification from a person for showing official favour. The original de facto complainant died before trial, but the prosecution proved its case through other witnesses, documentary evidence, and trap proceedings. The accused accepted the tainted money but claimed it was for audit fees—a defence unsupported by evidence. The Supreme Court held that a complainant's death is not fatal to prosecution; once illegal gratification is proved, Section 20 of the Prevention of Corruption Act raises a presumption that it was a motive for improper public duty. The accused failed to rebut this presumption. The Court dismissed the appeal and upheld the conviction and sentence.
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