The Supreme Court quashed the proceedings initiated against one of the accused in a bribery case linked to elections for the Telangana Legislative Council, observing that the records did not disclose his involvement in the alleged inducement of a legislator.

The Court was hearing Special Leave Petitions filed by the State questioning the validity of the High Court’s order that had set aside the registration of the crime against the accused. The petitioners argued that the FIR disclosed cognizable offences and that the High Court erred in quashing the case at the threshold.

The Bench of Chief Justice B.R. Gavai and Justice K. Vinod Chandran, however, found no reason to interfere. The Bench, while making these observations, remarked that, “we cannot but notice that there is nothing to connect A4 to the crime, but for a casual allegation raised on a call having been received by the complainant without any indication even of the time when such call was received. We find absolutely no reason to interfere with the order of the High Court and dismiss the Special Leave Petitions.”

Senior Advocate Menaka Guruswamy represented the State, while Advocate G. Prakash appeared for the complainant.

Background

The case arose from a complaint lodged by a Member of the Legislative Assembly alleging that he had been offered inducements to either abstain from voting or to support a particular party in the upcoming Legislative Council elections. According to the complaint, the legislator was initially approached with an offer of Rs. 2 crores along with a foreign travel ticket, followed later by an enhanced offer of Rs. 5 crores.

Based on the complaint, the Anti-Corruption Bureau registered an FIR under the Prevention of Corruption Act, 1988, after arranging for audio and video recordings of the alleged conversations. While multiple persons were implicated, the accused, whose case reached the Supreme Court, was apparently not present at the place of the alleged incident.

The High Court, after examining the material on record, held that there was no basis to proceed against him and quashed the case insofar as he was concerned.

Court’s Observation

The Supreme Court, while hearing the matter, observed that the only reference to the accused in the complaint was a vague allegation of a phone call purportedly made to the complainant, with no specific details of time or corroborative evidence. The subsequent allegations of an increased offer of money involved other individuals and were not linked to him. The Bench observed: “As we indicated earlier, the allegation made in the complaint against A4 is not in any way linked with the allegation of a higher offer having been made by another. The presence of A-4 is not reported when the alleged transaction occurred.”

The Court further clarified that while the High Court’s order was elaborate, it did not amount to a “mini-trial,” as alleged by the petitioners, but was instead supported by cogent reasons to quash the proceedings against the accused. While making these observations, the Bench remarked: “True, the learned Single Judge of the High Court has written an order running into pages, quoting various decisions and extracts made from them. Some of the decisions quoted were on faulty investigation which need not have been referred to. For reason, only of brevity having not been employed, we cannot set aside an order which though lengthy, has cited justifiable reasons to quash the proceedings.”

Conclusion

Finding no infirmity in the High Court’s order, the Supreme Court dismissed the Special Leave Petitions. The Court held that there was no justification to continue proceedings against the accused when no material connected him to the alleged bribery linked to the Legislative Council elections.

Cause Title: The State of Telangana Anti-Corruption Bureau Vs Jerusalem Mathai And Elvis Stephenson (Neutral Citation: 2025 INSC 1173)

Appearances

Petitioners: Senior Advocate Menaka Guruswamy with Advocates Sravan Kumar Karanam, AOR, Bhumika Yadav, Neha Rai, Kumar Abhishek.

Respondents: Advocate G. Prakash with Advocates Priyanka Prakash, AOR, Beena Prakash, Anoop R, Sravan Kumar Karanam, AOR, Arjun Krishnan, AOR.

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