Concurrent findings in corruption cases stand under Article 136 when trap evidence and recovery reliably prove demand and acceptance.

In an Article 136 appeal, the Supreme Court declined to disturb concurrent findings of guilt in a corruption case because the complainant and supporting witness were found reliable, the marked currency notes were recovered from the accused, and the defence explanation was disbelieved. Minor inconsistencies, non-examination of some witnesses, and the fact that certain witnesses were police officials did not undermine the substantive proof of demand, acceptance, and recovery. In the absence of perversity, gross misreading of evidence, or manifest injustice, the Court held that special jurisdiction under Article 136 did not justify reappraisal of facts and upheld the conviction under the Prevention of Corruption Act.

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Issues: Whether, in an appeal under Article 136, the Court should interfere with concurrent findings of guilt for corruption where the prosecution evidence showed demand, acceptance, and recovery of the bribe amount.

Analysis: The evidence of the complainant and the supporting witness was found reliable, and the recovery of the marked currency notes from the accused's clothes corroborated the prosecution version. The defence explanation was disbelieved by the courts below, and there was no material showing perversity, gross misreading of evidence, or manifest injustice so as to justify reappraisal of facts in the exercise of special jurisdiction under Article 136. The objections based on minor inconsistencies, non-examination of certain witnesses, and the fact that some witnesses were police officials did not displace the substantive proof of the charge.

Conclusion: The conviction for the offence under Section 5(1)(d) of the Prevention of Corruption Act was upheld, and interference was declined.

Ratio Decidendi: Concurrent findings of fact in a corruption case will not be disturbed under Article 136 unless they are vitiated by perversity, gross misreading of evidence, or manifest injustice, and reliable trap evidence with recovery of marked currency can sustain conviction.

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