Public servant status for licensed surveyors confirmed where statutory duties are controlled by the State and used for revenue records.

Licensed surveyors appointed under Section 18A of the Karnataka Land Revenue Act, 1964 were treated as performing a statutory public duty, not acting as private contractors. Their appointment, qualifications, training, licensing, fees, jurisdiction, scrutiny of work and possible cancellation of licence were all controlled by the State, and their survey sketches were used for official revenue administration. On that basis, the Court held that the work fell within public duty and that such surveyors came within the definition of public servant under Section 2(c) of the Prevention of Corruption Act, 1988.

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Issues: Whether a licensed surveyor appointed under Section 18A of the Karnataka Land Revenue Act, 1964 is a public servant for the purposes of the Prevention of Corruption Act, 1988.

Analysis: Licensed surveyors were appointed to perform the statutory task of preparing survey sketches for revenue administration, a function earlier carried out by Government survey staff. Their appointment, qualification, training, licensing, fee structure, jurisdiction, registration, scrutiny of work and cancellation of licence were all regulated by the State under the statutory scheme. The work performed by them was not that of a mere private contractor, but of a licencee discharging a duty controlled by the Government and used for official action in the revenue records. Such activity fell within the concept of public duty, and the statutory functions performed by them brought them within the definition of public servant under Section 2(c) of the Prevention of Corruption Act, 1988.

Conclusion: A licensed surveyor under Section 18A of the Karnataka Land Revenue Act, 1964 is a public servant within the meaning of the Prevention of Corruption Act, 1988.

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