Supreme Court: Allegations of ₹5 Crore Bribe Offer to MLA Before MLC Elections — SLPs Dismissed as No Case Made Out Against Accused
Case Name: The State of Telangana v. Jerusalem Mathai & Anr. (with connected SLP (Crl.) No. 9333 of 2016)
Date of Judgment: September 26, 2025
Citation: 2025 INSC 1173, SLP (Crl.) Nos. 5248 & 9333 of 2016
Bench: Hon’ble Chief Justice B.R. Gavai and Hon’ble Mr. Justice K. Vinod Chandran
Held: The Supreme Court dismissed the State’s Special Leave Petitions challenging the High Court’s order quashing proceedings against A4 in a bribery case linked to the 2015 MLC elections in Telangana. It held that the High Court had rightly quashed the FIR since there was no material connecting A4 with the alleged ₹5 crore bribe offer. The Court emphasized that quashing cannot be faulted merely because the High Court’s order was lengthy or cited multiple precedents. What mattered was that the allegations against A4 were vague, improbable, and unsupported by evidence.
Summary: The complainant, an MLA, alleged in his written complaint of 28.05.2015 that A4 had initially offered him ₹2 crore and a ticket abroad to abstain or vote for a particular party in the upcoming MLC elections, and later, a higher offer of ₹5 crore was conveyed by another. However, the FIR was registered only on 31.05.2015 under Section 12 of the Prevention of Corruption Act, 1988. During the alleged transaction on 31.05.2015, A4 was not present, nor was there evidence linking him to those who came to deliver the offer. The High Court quashed proceedings against A4, observing that mere casual allegations without specifics of time, place, or corroboration cannot sustain prosecution. On appeal, the State argued that the High Court conducted a “mini trial” in quashing, which the Supreme Court rejected, holding that absence of material against A4 justified the quashing. The Court reiterated that suspicion or casual reference cannot substitute proof of involvement in a corruption offence.
Decision: The Supreme Court dismissed the State’s appeals, upheld the High Court’s order quashing the FIR and proceedings against A4, and confirmed that there was no evidence connecting him with the alleged bribery attempt during the 2015 MLC elections.