News Citation : 2026 LN (HC) 204 | 2026:CGHC:11712
March 11, 2026 : The Chhattisgarh High Court has set aside the conviction of a Labour Inspector in a corruption case, holding that the prosecution failed to prove the essential elements of demand and acceptance of bribe beyond reasonable doubt.
In a judgment delivered on March 11, 2026, Chief Justice Ramesh Sinha allowed the appeal filed by Suresh Kurre, who had earlier been convicted by a Special Court under Section 7 of the Prevention of Corruption Act and sentenced to three years’ rigorous imprisonment along with a fine.
The case stemmed from a complaint alleging that Kurre demanded illegal gratification for facilitating payment to an NGO running skill development training programs in Jashpur district. Acting on the complaint, the Anti-Corruption Bureau conducted a trap operation in which ₹40,000 was allegedly recovered from the accused.
However, the High Court found serious gaps in the prosecution’s case. It noted that the allegation of demand rested solely on the complainant’s testimony, which was not corroborated by independent witnesses. Both panch witnesses admitted they neither heard the alleged demand nor clearly saw the exchange of money.
The Court also pointed out that the investigating agency failed to verify whether any payment was actually pending in favour of the complainant. Evidence on record showed that the authority to process and release payments lay with the Labour Officer, not the Labour Inspector, casting doubt on the very basis of the alleged demand.
Further, the prosecution relied on recorded conversations, but these were not forensically verified, nor properly proved in court. The High Court held that such electronic evidence could not be relied upon without proper authentication.
Reiterating settled law, the Court emphasized that mere recovery of tainted money is insufficient to sustain a conviction under the Prevention of Corruption Act unless demand and voluntary acceptance of bribe are clearly established.
It also took note of prior disputes between the complainant and the department, including recovery proceedings against the complainant, which raised the possibility of false implication.
In light of these deficiencies, the Court concluded that the foundational requirements of the offence were not proved. It granted the benefit of doubt to the accused and acquitted him of all charges, setting aside the trial court’s conviction and sentence.
Case Reference : CRA No. 2674 of 2025, Suresh Kurre S/o Late Atmaram Kurre v. State of Chhattisgarh; For Appellant: Mr. Abhishek Sinha, Senior Advocate, assisted by Mr. Ganshyam Patel, Advocate; For Respondent/State: Mr. Saurabh Sahu, Panel Lawyer.
