Delhi High Court Upholds Conviction Of Police Sub-Inspector In 1995 CBI Bribery Trap Case

The Delhi High Court has upheld the conviction and sentence awarded to a Delhi Police Sub-Inspector in a 1995 corruption case investigated by the Central Bureau of Investigation (CBI).

Justice Chandrasekharan Sudha refused to interfere with the trial court judgment convicting the Appellant under Sections 7 and 13(1)(d) read with Section 13(2) of the Prevention of Corruption Act, 1947, for demanding and accepting ₹5,000 illegal gratification while posted at Jama Masjid Police Station.

The case arose from a complaint lodged in October 1995 by the complainant, who alleged that the accused Sub-Inspector had demanded a bribe of ₹5,000 to avoid taking adverse action against him in a criminal case relating to fake university degrees.

Acting on the complaint, the CBI laid a trap at the Tis Hazari Courts, during which the bribe amount was recovered from a Head Constable acting at the instance of the accused.

Appellant challenged the conviction on grounds of alleged contradictions in witness testimonies, non-examination of certain material witnesses, defects in the handling of tape-recorded evidence, and non-compliance with provisions of the CBI Manual.

It was also argued that the alleged demand of bribe was not proved beyond reasonable doubt, which is a sine qua non for offences under the Prevention of Corruption Act.

Rejecting these submissions, the Court held that minor inconsistencies and procedural lapses did not go to the root of the prosecution case. It observed that the complainant's testimony was credible and corroborated in material particulars by other witnesses.

The Court further held that non-examination of certain witnesses, including the complainant's family members and public persons present at the court premises, was not fatal to the prosecution case.

On the issue of alleged violations of the CBI Manual, the Court reiterated that the Manual is an administrative order and does not have statutory force.

Thus finding no infirmity in the trial court order, the High Court dismissed the appeal.

Appearance: Mr. Manu Sharma, Sr. Advocate with Mr. Arjun Kakkar, Advocate for Appellant; Mr. Atul Guleria, SPP for CBI with Mr. Aryan Rakesh and Ms. Atreyi Chatterjee, Advocates for CBI

Case title: Manoj Kumar v. CBI

Citation: 2026 LiveLaw (Del) 140

Case no.: CRL.A. 733/2002

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