Valid prosecution sanction and proof of illegal gratification sustain corruption conviction on credible trap evidence and witness testimony.

Sanction for prosecution was valid because the competent authority considered the material facts, witness statements, FIR and relevant records before granting approval, and no particular form was required so long as satisfaction was shown. The corruption conviction was sustained because the complainant and trap witness consistently proved demand and acceptance of illegal gratification, corroborated by recovery of tainted currency and a positive phenolphthalein test. Concurrent findings of the lower courts on credibility and guilt were upheld, leaving the conviction and sentence undisturbed.

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Issues: (i) Whether the sanction for prosecution was valid and reflected due application of mind. (ii) Whether the evidence established demand and acceptance of illegal gratification so as to sustain the conviction.

Issue (i): Whether the sanction for prosecution was valid and reflected due application of mind.

Analysis: The sanction order recited the material facts, the witness statements, the FIR, and the relevant official documents, and showed that the competent authority considered the materials before according sanction. A valid sanction does not require any particular form, but it must show that the authority was satisfied on the basis of the facts placed before it.

Conclusion: The sanction for prosecution was valid and the objection was rejected.

Issue (ii): Whether the evidence established demand and acceptance of illegal gratification so as to sustain the conviction.

Analysis: The complainant and the trap witness consistently stated that the accused demanded the bribe, received the amount, and the trap evidence corroborated recovery of the tainted currency and the positive phenolphthalein test. The courts below had concurrently appreciated the evidence and found the prosecution version trustworthy.

Conclusion: The evidence proved demand and acceptance of illegal gratification and the conviction was sustained.

Final Conclusion: The concurrent findings of guilt were upheld and the conviction and sentence remained undisturbed.

Ratio Decidendi: A sanction for prosecution is valid when the sanctioning authority considers the material facts and relevant records and records satisfaction, and a conviction for corruption can be sustained on credible evidence of demand and acceptance corroborated by trap recovery.

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