Introduction
In a significant Judgment delivered on November 10, 2025, a Division Bench of the Supreme Court comprising Justice Vikram Nath and Justice Sandeep Mehta disposed of the case of T. Manjunath v. The State of Karnataka and Anr. (SLP(Crl.) Nos. 11160-11161 of 2024). The Appeals challenged a Karnataka High Court order dated July 26, 2024, which had reversed Trial Court’s discharge Order in a corruption case under the Prevention of Corruption Act, 1988. The Judgment addresses two critical legal questions: the evidentiary value of exoneration in departmental proceedings vis-à-vis criminal prosecution and the jurisdictional competence of authorities granting prosecution sanction under Section 19 of the PC Act.
Factual Background
The case originates from a trap laid by the Lokayuktha Police in June 2012, when the Accused-Appellant, T. Manjunath, served as Senior Inspector of Motor Vehicles at the RTO Office, K.R. Puram, Bengaluru. The trap operation allegedly caught Manjunath demanding and accepting illegal gratification of Rs. 15,000 through a private intermediary, H.B. Mastigowda, to facilitate the movement of twelve tipper trucks. Following the trap, Crime No. 48/2012 was registered under Sections 7, 8 and 13 of the PC Act and the Commissioner of Transport granted sanction for prosecution under Section 19 of the Act.
The Trial Court, in its August 2017 order, discharged both accused primarily on the ground that the sanction was invalid. The Court held that since Manjunath was a Group-B officer appointed by the State Government, only the State Government and not the Commissioner of Transport, constituted the competent sanctioning authority. While the Trial Court permitted the investigating agency to file a fresh chargesheet after obtaining proper sanction, the High Court reversed this decision in July 2024, holding that the Commissioner was indeed the competent authority under a February 2010 notification.
Court’s Decision and Analysis
The Supreme Court squarely rejected the Appellant’s first submission, drawing a sharp distinction between disciplinary and criminal proceedings. The Bench observed that while both processes might arise from the same factual matrix, they operate in distinct jurisdictional spheres with fundamentally different objectives, procedures and evidentiary standards.
The Court noted that the disciplinary authority’s exoneration was based primarily on the hostility of three key witnesses i.e. the complainant, shadow witness and colleague, who disclaimed knowledge of the bribe demand. However, the investigating officer’s testimony remained consistent and unshaken. The Supreme Court emphasized its consistent jurisprudence that in trap cases, the hostility of complainants and associate witnesses does not automatically derail prosecution, as convictions can be sustained on the sole testimony of a credible trap-laying officer.
Critically, the Bench highlighted that witnesses face perjury consequences in criminal trials, which might motivate them to testify truthfully despite having been hostile in departmental inquiries. This possibility, combined with the different standards of proof, rendered the departmental “clean chit” inconclusive for criminal proceedings.
The second issue presented a more complex question of statutory interpretation. Section 19(1) of the PC Act mandates that sanction must come from “the authority competent to remove” the public servant from office. The Parties presented contradictory documentary evidence regarding Manjunath’s actual appointing authority.
The Supreme Court clarified the scope of Section 19(4) Explanation, which includes “competency of the authority” within the definition of “error.” The Bench held that this Explanation operates only during appellate or revisional scrutiny of a trial court’s findings, not at the original trial stage when the trial court examines sanction validity in limine. The Court distinguished the precedents relied upon by the State, noting they addressed challenges to final orders rather than preliminary discharge applications.
Faced with conflicting unverified documents, the Appellant’s December 1991 memorandum suggesting State Government appointment and the State’s February 2010 notification suggesting Commissioner appointment, the Supreme Court found itself unable to resolve the factual dispute. The Bench decided to remand the matter to the Trial Court for fresh determination of the appointing authority question.
• Remand Directions
The Supreme Court disposed of the Appeals by:
1. Rejecting the plea for discharge based on departmental exoneration
2. Setting aside the High Court’s findings on sanction validity
3. Remitting the case to the trial court for limited adjudication on the sanction’s competence after examining original appointment records
4. Directing that if sanction is found invalid, the chargesheet be returned for fresh sanction; if valid, trial proceeds
Conclusion
This Judgment reinforces the autonomy of criminal prosecution from administrative disciplinary processes in corruption cases. By holding that departmental exoneration does not foreclose criminal liability, the Supreme Court has fortified the PC Act’s deterrent framework, ensuring that technical evidentiary failures in internal inquiries do not immunize public servants from criminal accountability.
Simultaneously, the ruling provides crucial clarification on Section 19 PC Act, emphasizing that jurisdiction-competence challenges must be resolved at trial based on substantive evidence regarding appointing authority, not brushed aside by appellate courts through broad interpretations of the Explanation clause.
For Karnataka’s anti-corruption machinery, the Judgment underscores the necessity of meticulous verification of sanctioning authority at the investigation stage itself, preventing procedural loopholes that could derail legitimate prosecutions. This case serves as a precedent that trap case convictions can proceed despite witness hostility, protecting the integrity of anti-corruption operations.
YASH HARI DIXIT
ASSOCIATE
THE INDIAN LAWYER & ALLIED SERVICES
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