SUPREME COURT QUASHES CORRUPTION CHARGES DUE TO LACK OF EVIDENCE

by Nancy Sharma | Feb 28, 2025

Supreme Court ruling on corruption charges, emphasizing the need for direct evidence of bribery.

Supreme Court clarifies that policy deviations without proof of bribery do not constitute corruption under the law.

SUPREME COURT QUASHES CORRUPTION CHARGES DUE TO LACK OF EVIDENCE

ASPECTS	DETAILS
Case Title	Dileepbhai Nanubhai Sanghani vs. State of Gujarat & Anr. (2025 INSC 280)
Introduction	The case concerns allegations of corruption against Dileepbhai Nanubhai Sanghani, a former Gujarat minister, for allotting fishing contracts without a tender process, violating government policy. He challenged the High Court’s refusal to quash the criminal proceedings.
Factual Background	Sanghani, as the Minister of Fisheries, allegedly allotted state-owned reservoirs for fishing without following the required tender process, leading to a significant loss to the state exchequer. The complainant, a fish trader, filed a case claiming corruption. The High Court canceled the grants and ordered a tender-based allocation. The Special Court and High Court found a prima facie case against the accused.
Legal Issues	Whether the accused demanded or accepted illegal gratification under the Prevention of Corruption Act, 1988. Whether the deviation from the tender process constituted corruption. Whether there was enough material to sustain charges against the accused under Sections 7, 8, 13(1)(a), 13(1)(d), and 13(2) of the Act.
Applicable Law	Prevention of Corruption Act, 1988 (Sections 7, 8, 13(1)(a), 13(1)(d), and 13(2)). Code of Criminal Procedure, 1973 (Section 482 for quashing proceedings). Supreme Court precedents: Neeraj Dutta vs. State (NCT of Delhi) (2023), Dipakbhai Patel vs. State of Gujarat (2019), Sajjan Kumar v.s CBI (2010).
Analysis	The investigation found no direct evidence that Sanghani demanded or accepted a bribe.The High Court relied on circumstantial evidence but overlooked that the tribal welfare policy allowed direct grants at an upset price.The Special Court denied discharge without assessing whether the accused’s actions met the corruption law’s criteria.The Supreme Court ruled that mere violation of policy without proof of bribe demand or acceptance is insufficient to sustain corruption charges.
Conclusion	The Supreme Court allowed the appeal, holding that the prosecution failed to prove a demand or acceptance of illegal gratification. It quashed the criminal proceedings against Sanghani while clarifying that the trial against the first accused could continue based on the available evidence.
Current Scenario	The case has been closed against Sanghani, reaffirming that policy deviations alone do not constitute corruption unless linked to direct evidence of illegal gratification. However, proceedings against the first accused (Minister of State) continue.

CASE SUMMARY – In this case Supreme Court quashes corruption charges due to lack of evidence in which Dileepbhai Nanubhai Sanghani, a former Gujarat minister is accused of corruption for allotting fishing contracts without a tender process, allegedly causing a ₹21 crore loss to the state. The complainant challenged the allotments, leading the Gujarat High Court to cancel them. The Special Court and High Court found a prima facie case, but the Supreme Court quashed proceedings against Sanghani, citing a lack of evidence of demand or acceptance of bribes. The Court held that policy violations alone do not constitute corruption and reaffirmed the need for substantive proof under the Prevention of Corruption Act, 1988.

“Policy deviations are not corruption unless proven with direct evidence of bribery or illegal gratification.

SOURCE –

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Written By Nancy Sharma

I am Nancy Mahavir Sharma, a passionate legal writer and a judicial service aspirant who is interested in legal researching and writing. I have completed Latin Legum Magister degree. I have been writing from past few years and I am excited to share my legal thoughts and opinions here. I believe that everyone has the potential to make a difference.