Mere recovery of tainted cash cannot lead to conviction in bribery case: Chhattisgarh High Court

The Chhattisgarh High Court has acquitted an education department official in a bribery case dating back over a decade, ruling that the mere recovery of tainted currency notes without concrete proof of a bribe demand is not sufficient for conviction. Justice Naresh Kumar Chandravanshi, hearing a single Bench, overturned a 2017 trial court order that had sentenced Murali Prasad Choudhary, an accountant at the District Education Officer (DEO) office in Surajpur district, to imprisonment.

The High Court in Bilaspur issued the order on September 18, 2026. Choudhary had contested the special court’s conviction under the Prevention of Corruption Act, 1988. The prosecution alleged that in 2014, DEO Choudhary demanded ₹15,000 from Mohit Ram Rajwade, president and manager of Maa Saraswati Shiksha Samiti, for recognizing a school run by the organization.

Choudhary allegedly asked Rajwade to pay ₹5,000 immediately, of which a portion of ₹4,900 was reportedly paid. Rajwade complained to the Anti-Corruption Bureau (ACB) in Bilaspur, and they laid a trap on June 30, 2014, where Choudhary allegedly accepted ₹8,000 from Rajwade, counted the notes, and kept them in his trousers. The prosecution argued that Choudhary accepted the bribe after the demand, but the High Court held that the prosecution failed to prove the demand beyond reasonable doubt.

The court noted that the complainant, Rajwade, turned hostile and contradicted his earlier testimony, stating that Choudhary never demanded any bribe. Furthermore, the court observed that other witnesses, including Kunwar Sai, also turned hostile and did not support the prosecution’s case. The High Court ruled that the prosecution had to establish both demand and acceptance of illegal gratification for a conviction, which it failed to do in this case.