New Delhi, September 9, 2026: The Supreme Court has expressed concern over the long pendency of corruption cases, observing that courts are often burdened by voluminous evidence that is unnecessary and irrelevant.
A bench of Justice JB Pardiwala and Justice Vinod K Chandran made the observation while acquitting a former government store in-charge who was convicted under the Prevention of Corruption Act, 1988, in a 1993 case involving fake medicine supply bills, Live Law reports.
Too Much Evidence Little Relevance
The court observed that corruption trials often involve a large amount of evidence, which can intimidate courts and distract from the actual allegations.
"We cannot but notice that in corruption cases voluminous evidence is led, which is often intimidating to the Court, especially since many aspects attempted to be led in evidence are way off the mark, in providing a substantiation of the allegation, or to bring home the guilt of the accused-public servant," the bench said.
The court noted that in the present case, the prosecution examined 62 witnesses, most of whom were irrelevant to the issue before it.
The case arose from a complaint filed by the Veterinary Department of Assam, alleging a loss of Rs 5,97,200 due to the submission of false medicine bills for supplies that were never made. Payments were allegedly released to a fictitious firm.
Seven persons were chargesheeted in the case. The trial court convicted four and acquitted three. Later, the Gauhati High Court acquitted the accountant but upheld the conviction of the store in-charge and storekeeper under Section 13(1)(d) of the Prevention of Corruption Act.
The appellant then approached the Supreme Court against the High Court's decision.
Conviction Requires Financial Gain
The Supreme Court said the case depended on a narrow question: whether a conviction under Section 13(1)(d) of the Prevention of Corruption Act read with Section 120B of the Indian Penal Code could be sustained when there was a clear finding that the appellant had not obtained any pecuniary advantage.
While examining Section 13(1)(d) of the Prevention of Corruption Act, the bench observed that the provision requires a public servant to obtain a valuable thing or pecuniary advantage for himself or another through corrupt or illegal means, abuse of official position, or without public interest.
"Without a pecuniary advantage, there could be no conviction under Section 13(1)(d), which the High Court has categorically found, does not exist in the present case," the court said.
The bench noted that the evidence, if anything, could have supported charges under the Indian Penal Code, but the High Court had failed to consider this aspect. However, since the Central Bureau of Investigation had not challenged the appellant's acquittal under the IPC offences, the benefit of that lapse had to go to the appellant.
The court also pointed out that while the prosecution examined 62 witnesses, the High Court's judgment referred to only nine of them.
"In this case the prosecution has examined 62 witnesses, obviously to no avail, since the High Court refers to only nine of such witnesses; eight being the in-charge of the Veterinary Dispensaries in the various parts of the State, at the relevant period to prove the supply of medicines having not been effected, as per the challans issued and bills passed. The one other witness referred to is the actual owner of the firm, who was the supplier, who appeared and denied receipt of any money or even the supply of medicines," the bench observed.
Court Questions Missing Money Trail
The Supreme Court also highlighted that the investigation did not examine the money trail to find out how the disbursed funds were routed.
The bench said corruption cases have a history of prolonged trials, often because of excessive evidence being presented without focusing on material aspects of the case.
"We do not see any investigation having been taken to find out the money trail when the amounts were so disbursed from the department. Prosecution in corruption cases have a history of long pendency; especially because of the voluminous evidence led, which often is unnecessary and as we noticed, mostly irrelevant," the court said.
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The court added that it found no reason to uphold the conviction under the provision invoked by the High Court.
Allowing the appeal, the Supreme Court acquitted the appellant of the charges upheld by the High Court and directed his release.
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