Anti-corruption investigation and statutory presumption upheld, with concurrent findings on receipt of money left undisturbed.

The Delhi Special Police Establishment Act was read as supplementing, not excluding, the ordinary criminal law power of investigation, and the Prevention of Corruption Act was treated as operating alongside the procedural code; an investigation by the Delhi anti-corruption branch was therefore not invalid merely because it was not exclusive to that agency. On the evidence, receipt of money attracted the statutory presumption under anti-corruption law, and the defence explanation was found unsatisfactory. Concurrent factual findings by the trial court and High Court were not disturbed, and the conviction was sustained.

---

---

Issues: (i) Whether the Delhi Special Police Establishment had exclusive jurisdiction to investigate the corruption offences, so as to render the investigation by the Delhi anti-corruption branch illegal and the trial vitiated; (ii) Whether the conviction could be interfered with on the evidence, including the statutory presumption and the defence explanation for receipt of money.

Issue (i): Whether the Delhi Special Police Establishment had exclusive jurisdiction to investigate the corruption offences, so as to render the investigation by the Delhi anti-corruption branch illegal and the trial vitiated

Analysis: The statutory scheme of the Delhi Special Police Establishment Act empowers the Central Government to notify offences for investigation by that establishment and to extend its powers, but it does not by express words or necessary implication divest the regular police of their general power to investigate offences under the criminal law. The Prevention of Corruption Act also contemplates investigation by specified police officers and operates alongside the criminal procedure regime. The two enactments were read as supplementary and harmoniously functioning provisions, and an irregularity in investigation, even if assumed, would not by itself invalidate a competent trial absent miscarriage of justice.

Conclusion: The investigation by the Delhi anti-corruption branch was held to be lawful, and the objection to the trial on that ground failed.

Issue (ii): Whether the conviction could be interfered with on the evidence, including the statutory presumption and the defence explanation for receipt of money

Analysis: The appellant admitted receipt of money on the relevant date, which attracted the statutory presumption under the anti-corruption law. The trial court and the High Court both found the defence explanation unsatisfactory and the defence witnesses unreliable. No compelling ground was shown for disturbing the concurrent appreciation of oral evidence or for reappraising the facts in appeal.

Conclusion: The conviction was upheld and no interference with the findings of fact was warranted.

Final Conclusion: The appeal was found to be devoid of merit, the conviction was sustained, and the judgment left the respondent's case intact.

---