The Rajasthan High Court has rejected the second bail application filed by former Income Tax Appellate Tribunal (ITAT) Judicial Member S. Seethalakshmi in a corruption case investigated by the Central Bureau of Investigation (CBI), observing that the allegations involved serious accusations of judicial corruption and acceptance of illegal gratification for passing a favourable order in a pending tax matter. 

The bench of Justice Chandra Prakash Shrimali has observed that  there was no absolute legal mandate that an accused must necessarily be granted bail merely because sanction under Section 19 of the Prevention of Corruption Act was not issued within four months. The Court clarified that the precedents cited by the defence did not create any automatic or indefeasible right to bail in such circumstances. 

The accused had earlier moved a first bail application, which had already been dismissed by the High Court on 25 February 2026. In the second bail plea, the defence argued that there had been a change in circumstances after filing of the first application and therefore a fresh plea under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS) was maintainable. 

During the hearing, counsel for the accused contended that although the charge-sheet had been filed on 22 January 2026, prosecution sanction had not been granted within the prescribed period contemplated under Section 19 of the Prevention of Corruption Act. It was argued that sanction should ordinarily be granted within three months, extendable by one additional month, and failure to do so violated the accused’s rights under Article 21 of the Constitution. Reliance was placed on several decisions of the Rajasthan High Court, Supreme Court and Delhi High Court to contend that prolonged delay in sanction constituted a valid ground for grant of bail. 

The defence further submitted that co-accused persons had already secured bail and that the alleged recovery of bribe money was not made directly from the possession of the accused. It was also argued that the prosecution had not clearly established whether the black bag allegedly containing cash was actually recovered from her official vehicle. The accused additionally relied on humanitarian grounds, stating that she had been transferred from Jaipur to Jabalpur and that her 89-year-old father-in-law was hospitalised and dependent on her care. 

However, the prosecution strongly opposed the bail plea and alleged that the accused, while serving as a Judicial Member of the ITAT, had passed an order in favour of a company and granted relief from a penalty of approximately ₹90 crore in exchange for illegal gratification. According to the CBI, an amount of ₹30 lakh was accepted through a co-accused chartered accountant and was later recovered from the accused’s government vehicle parked at her residence. 

The prosecution also alleged that CCTV footage and the statement of the government vehicle driver recorded under Section 183 BNSS supported the recovery and movement of the alleged bribe amount. Further, during searches conducted at the accused’s residence, investigators allegedly recovered a necklace and an iPhone 17 Pro Max (512 GB), which the prosecution claimed were accepted as gifts forming part of the illegal gratification. 

While considering the matter, the High Court reiterated that bail decisions in corruption cases must take into account the gravity of allegations, the nature of evidence, the possibility of influencing witnesses, and the overall impact on public confidence in institutions. The Court noted that the allegations related to misuse of a judicial office and acceptance of bribe money for deciding a pending matter before the tribunal. 

The Court specifically observed that the material collected during investigation prima facie indicated that ₹30 lakh had been recovered from the accused’s official vehicle and that the prosecution had also relied upon witness statements and CCTV evidence. The Court further noted that expensive articles allegedly received as gifts were also recovered from her possession during investigation. 

The Court also refused to accept the plea based on parity with co-accused persons, observing that the role attributed to the accused was distinct and more serious in nature. It held that the facts and circumstances of the co-accused could not be equated with those relating to a judicial officer accused of accepting bribes in connection with adjudicatory functions. 

Relying upon decisions including Niranjan Hemchandra Sashittal v. State of Maharashtra, Manoj Narula v. Union of India and Jatin Salwan v. CBI, the Court held that allegations of corruption involving public offices and judicial institutions required strict scrutiny and that grant of bail at this stage would not be appropriate. 

Consequently, the Rajasthan High Court dismissed the second bail application while directing the trial court to proceed expeditiously with the matter and ensure presence of prosecution witnesses for early disposal of the case. 

Case Details

Case Title: S. Seethalakshmi Versus CBI

Case No.: S.B. Criminal Miscellaneous 2nd Bail Application No. 6846/2026

Date: 13/05/2026

Counsel For Petitioner: Swadeep Hora

Counsel For Respondent: Pradeep Kumar, Special PP

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