Allahabad High Court Grants Bail in Corruption Case, Highlights Procedural Lapses

Bail Granted to Suresh Prakash Gautam Amidst Doubts Over Trap Proceedings and Investigation Irregularities

In a significant ruling, the Allahabad High Court has granted bail to Suresh Prakash Gautam, a Labour Enforcement Officer, accused of demanding and accepting a bribe. The decision, delivered by Justice Sameer Jain on December 1, 2025, highlights substantial procedural lapses in the corruption investigation, raising questions about the integrity of the trap proceedings conducted by the police.

Gautam, who was allegedly caught red-handed by the trap team, was accused of soliciting a bribe of Rs. Fifteen Thousand to settle a claim. The prosecution's case faced skepticism due to several procedural irregularities. Notably, the court observed that the bribe money was not sealed at the spot of recovery, and critical procedural steps, such as washing of hands and preparation of the recovery memo, were executed at the police station rather than the scene, undermining the credibility of the trap.

The court emphasized the principle of presumption of innocence, noting that bail should not be denied for punitive or preventive reasons unless compelling evidence dictates otherwise. Justice Jain pointed out that the applicant had no prior criminal history and had been in custody for over three months, which further supported the decision to grant bail.

Additionally, Gautam had previously filed a complaint alleging a conspiracy against him, lending credence to his claims of false implication. The court also noted a significant oversight in the investigation regarding a large sum of money, Rs. Twenty One Lacs Fifty Thousand, recovered from Gautam's residence, which the Investigating Officer failed to probe adequately.

In his judgment, Justice Jain directed the Principal Secretary (Home) and the Director General of Police, Uttar Pradesh, to ensure procedural sanctity during trap proceedings, urging them to conduct crucial steps such as the sealing of recovered money and hand washing at the trap site itself.

The court's decision to grant bail does not reflect on the merits of the case, and the trial will proceed with the applicant required to adhere to specific conditions, including regular court appearances and refraining from tampering with evidence or engaging in criminal activities.

This ruling underscores the necessity for meticulous adherence to procedural standards in corruption investigations, ensuring that justice is both served and seen to be served.

Bottom Line:

Bail granted in a corruption case under Section 7 of the Prevention of Corruption Act, 1988, considering doubts over the trap proceedings, previous complaint by the applicant alleging conspiracy, and the accused's claim of the source of recovered money.

Statutory provision(s): Prevention of Corruption Act, 1988 Section 7

Suresh Prakash Gautam v. State of U.P., (Allahabad) : Law Finder Doc Id # 2820216