State by Lokayuktha Police v. K. Rangayya 2026 INSC 574 -Prevention of Corruption Act - Undue Advantage For Another Person

Prevention of Corruption Act, 1988 — Section 7(a) read with Explanation 2 -An attempt to obtain undue advantage whether for oneself or for another, and whether directly or through intermediaries is equally culpable under Section 7 read with Explanation 2 of the Act. (Para 27) It is not necessary that the public servant himself has to obtain or accept or attempt to obtain undue advantage for himself only, but such undue advantage can be obtained or accepted or attempted to be obtained for “another person” also. (Para 21) Further, an attempt to obtain a bribe through subordinates who are also public servants, is a kind of indirect corruption. (Para 23-24)

Prevention of Corruption Act, 1988 — Section 7 - Mere demand or solicitation, therefore, by a public servant may amount to commission of an offence under Section 7 of the PC Act. The word ‘attempt’ is to imply no more than a mere solicitation, which, again, may be made as effectually in implicit or in explicit terms. 

Code of Criminal Procedure, 1973 — Section 482 — The existence of prior disputes between the parties does not, in and of itself, constitute a ground for quashing the FIR, particularly when the allegations, taken at face value, disclose a prima facie cognizable offence. (Para 32) Prevention of Corruption Act, 1988 — Section 7-  Whether evidence ultimately supports the inference of demand and attempt to obtain an undue advantage is a question to be resolved by the trial court upon a full consideration of all the evidence. It is not a matter to be pre-empted and foreclosed at the stage of quashing. The Complainant's motive, if any, is a matter that can be tested by the defence in the course of the trial by way of cross-examination or otherwise. (Para 32)

Prevention of Corruption Act, 1988 — Section 7- In the absence of evidence of the complainant, the inference of culpability under Section 7 may be drawn from circumstantial evidence. (Para 30)