Income Tax Assistant Convicted In Rs. 600 Bribery Case: Patna High Court

The Patna High Court has upheld the conviction and sentence of Ram Narayan Singh, a former Income Tax Assistant posted at Sasaram, for demanding and accepting a bribe of ₹600 for processing an income tax refund. The bench of Justice Alok Kumar Pandey dismissed Criminal Appeal affirming the judgment passed by the Special Judge, CBI-I, Patna, under the Prevention of Corruption Act, 1988. The case arose from a complaint filed in March 2011 by Arun Kumar Srivastav, a field worker with Sahara India. The complainant alleged that although his total income for the financial year 2008-09 was only ₹50,905, tax of ₹5,826 had been deducted from his commission. After filing his income tax return seeking a refund of the deducted amount, he repeatedly visited the Income Tax Office at Sasaram. According to the prosecution, Ram Narayan Singh, then posted as a Tax Assistant, demanded ₹600 as illegal gratification—approximately 10% of the refund amount—for processing the refund. Unwilling to pay the bribe, the complainant approached the Central Bureau of Investigation (CBI). After verification of the complaint, the CBI registered an FIR under Section 7 of the Prevention of Corruption Act and laid a trap on 17 March 2011. A trap team comprising CBI officers and independent witnesses was constituted. Phenolphthalein-treated currency notes of ₹600 were handed over to the complainant with specific instructions. During the trap at the Income Tax Office, Sasaram, the accused allegedly demanded and accepted the bribe. Upon receiving the pre-arranged signal, the CBI team intervened. The tainted money was recovered, and chemical tests on the accused’s hands turned pink, confirming contact with the treated currency. Subsequent forensic examination by the CFSL, Kolkata, corroborated the prosecution’s case. Following investigation, a charge-sheet was filed, and the trial court convicted the accused under Section 7 and Section 13(2) read with Section 13(1)(d) of the Prevention of Corruption Act. He was sentenced to six months’ rigorous imprisonment under Section 7 and one year’s rigorous imprisonment under Section 13, along with fines, with sentences directed to run concurrently. In appeal, the defence argued that the appellant was not responsible for processing refunds of the relevant ward and that there were inconsistencies in the complainant’s testimony regarding the timing of the complaint and registration of the FIR. It was also contended that the evidence did not conclusively establish demand and acceptance of illegal gratification. Justice Alok Kumar Pandey, after a detailed examination of the evidence, rejected the defence arguments. The Court held that the prosecution had proved demand, acceptance, and recovery of bribe beyond reasonable doubt through consistent oral testimony, documentary evidence, and scientific corroboration. The complainant, shadow witness, independent witnesses, and CBI officers gave cogent and mutually corroborative evidence. The presumption under Section 20 of the Prevention of Corruption Act was rightly drawn once recovery of tainted money was established, and the accused failed to rebut the presumption. Minor inconsistencies pointed out by the defence did not go to the root of the case. The appellant, as a public servant, was in a position to facilitate the refund and had abused his official position for pecuniary gain. The Court also relied on Supreme Court precedents, including Neeraj Dutta v. State (NCT of Delhi) and Krishna Ram v. State of Rajasthan, reiterating that proof of demand and acceptance is sine qua non for conviction under corruption laws, which stood satisfied in the present case. Finding no illegality or perversity in the trial court’s judgment, the Patna High Court dismissed the appeal and upheld the conviction and sentence of Ram Narayan Singh. Case Details Case Title: Ram Narayan Singh Versus State of Bihar Case No.: Criminal Appeal (SJ) No.468 Of 2025 Date: 22/12/2025 Counsel For Petitioner: Sumit Kumar Singh Counsel For Respondent: Mukeshwar Dayal Click Here To Read Order Read More: CGST Ahmedabad | Vodafone Idea Slapped With Rs. 638 Crore GST Penalty

Income Tax Assistant Convicted In Rs. 600 Bribery Case: Patna High Court

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