Supreme Court Holds That Exoneration in Departmental Proceedings Does Not Automatically Quash Criminal Prosecution Based on the Same Allegations

Case Name: The Karnataka Lokayuktha, Bagalkote District, Bagalkot v. Chandrashekar & Anr.
Citation: 2026 INSC 31
Date of Judgment/Order: 06 January 2026
Bench: Justice Ahsanuddin Amanullah and Justice K. Vinod Chandran

Held: The Supreme Court held that exoneration of a delinquent employee in departmental proceedings does not automatically warrant quashing of criminal prosecution arising from the same allegations, particularly when the exoneration is not on merits but is attributable to deficiencies in the conduct of the enquiry, and when the criminal case rests on independent evidence requiring adjudication on the higher standard of proof applicable to criminal trials.

Summary: The appeal arose from a judgment of the High Court quashing criminal proceedings against a public servant accused of demanding and accepting bribe money, on the ground that he had been exonerated in departmental enquiry. The Supreme Court examined the factual matrix of a successful anti-corruption trap, recovery of tainted money, and the parallel initiation of disciplinary and criminal proceedings. Analysing the jurisprudence laid down in Radheshyam Kejriwal and Ajay Kumar Tyagi, the Court distinguished cases where exoneration is on merits from those where it results from procedural lapses or insufficient enquiry. It emphasised that disciplinary proceedings and criminal prosecution are independent, governed by different standards of proof, and conducted by different authorities, and that shortcomings in departmental enquiry cannot foreclose a criminal trial supported by substantive evidence.

Decision: The appeal was allowed, the order of the High Court quashing the criminal proceedings was set aside, and the Supreme Court permitted continuation of the criminal prosecution against the respondents, while clarifying that the concluded departmental proceedings would not be reopened but that any conviction in the criminal case would entail service consequences in accordance with law, with all pending applications disposed of.