T. Manjunath vs The State of Karnataka; 2025 INSC 1356 -Prevention of Corruption Act - Sanction

Prevention of Corruption Act 1988 - Section 19- The Explanation to Section 19(4) would become relevant and come into play only when the question of validity or otherwise of the sanction is under scrutiny before the appellate or the revisional forum as provided in sub-Section (3) of Section 19. (Para 38)

Criminal Trial - Prevention of Corruption Act - Exoneration in the departmental proceedings does not, ipso facto, furnish a ground for dropping the criminal charges more particularly in Trap Cases.(Para 33) The mere fact that a decoy/complainant in a trap case turns hostile would not adversely affect the case of prosecution and that conviction can be based even on the evidence of the trap laying officer, if found reliable and trustworthy. (Para 30) When a witness deposing on oath in a criminal trial resiles from the original version and does not support the prosecution case, he would be liable to face prosecution for perjury. Under this pressure, the witness may choose to speak the truth. Thus, the mere fact that some of the witnesses did not support the department’s case in the disciplinary proceedings would, by itself, not give any assurance that they would behave in the same manner at the criminal trial. (Para 31)