Supreme Court Expands Liability under Section 7 of Prevention of Corruption Act – PSI Held Accountable for Indirect Bribe

Overview The Supreme Court has clarified that a public servant can be liable for corruption even if he does not personally demand or receive a bribe. The judgment restores a FIR against a Karnataka Police Sub‑Inspector (PSI) accused of routing a ₹50,000 bribe through sub‑ordinates. Key Developments Bench of Justices Sanjay Karol and N. Kotiswar Singh set aside the Karnataka High Court order that had quashed the FIR. The Court held that Section 7 of the Prevention of Corruption Act covers attempts to obtain an undue advantage through third parties. Explanation 2 to Section 7 was pivotal; it makes it immaterial whether the advantage is sought for another person or through a middleman. The judgment emphasises that the mere “veiled demand” for illegal gratification, even if the official does not receive the money, satisfies the prima‑facie test of the offence. The FIR, registered by the Lokayukta police, now proceeds to trial. Important Facts • Respondent 1, Rangayya , a Sub‑Inspector at Siruguppa police station, threatened a complainant for allegedly selling ration rice illegally. • Through a subordinate, a demand of ₹50,000 was made on Rangayya’s instruction, with the instruction to “make those boys happy”. • The Karnataka High Court dismissed the FIR on the ground that the PSI neither directly demanded nor accepted the bribe. • The Supreme Court rejected this narrow view, stating that the statutory language of Explanation 2 expressly includes indirect or third‑party corruption. UPSC Relevance The case illustrates the breadth of anti‑corruption law in India, a frequent topic in GS 2 (Polity) . Understanding the scope of Explanation 2 helps aspirants answer questions on statutory interpretation, federal‑state relations (role of Lokayukta ), and the mechanisms to curb bureaucratic corruption. Way Forward • Courts are likely to apply this expansive interpretation to other cases involving indirect bribery, thereby closing loopholes for senior officials. • State anti‑corruption bodies must ensure that complaints against public servants, even when mediated through sub‑ordinates, are investigated promptly. • For UPSC preparation, focus on the interplay between statutory provisions (Section 7, Explanation 2) and judicial pronouncements, as they shape the legal framework governing public accountability.