Trap witness testimony and accused conduct can support bribery conviction without mandatory independent corroboration.

A truthful trap witness need not be treated as an accomplice merely because he participated in the trap, so independent corroboration is not an invariable legal requirement in bribery cases. Where the witness is found reliable, conviction may rest on his uncorroborated evidence, and hostile evidence is usable only to the extent permitted by law. The accused's silence, perplexity, or reaction when confronted by the investigating officer was treated as admissible conduct, not a barred statement, and could corroborate the prosecution case along with prompt recovery of the tainted money and surrounding circumstances. The conviction was upheld on the whole evidence.

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Issues: (i) Whether the testimony of a trap witness required independent corroboration before sustaining conviction for bribery-related offences; (ii) Whether the conduct of the accused when confronted by the investigating officer was admissible and could be used as corroborative evidence.

Issue (i): Whether the testimony of a trap witness required independent corroboration before sustaining conviction for bribery-related offences.

Analysis: A trap witness is not to be treated as an accomplice merely because he participated in laying the trap, though his evidence may call for careful scrutiny as that of an interested witness. Corroboration is not an invariable rule; it depends on the facts and the Court's assessment of truthfulness. Where the witness is found reliable, conviction can rest on his uncorroborated evidence. The evidence of hostile witnesses and their prior statements to the police were used only in the manner permitted by law, and the Court rejected the attack on the complainant's credibility.

Conclusion: Independent corroboration was not legally mandatory, and the complainant's evidence was accepted as truthful and sufficient.

Issue (ii): Whether the conduct of the accused when confronted by the investigating officer was admissible and could be used as corroborative evidence.

Analysis: A distinction was drawn between an inadmissible statement made to a police officer during investigation and admissible conduct influenced by a relevant fact. Silence, perplexity, or other reaction of the accused on being challenged was treated as conduct within the meaning of the Evidence Act and not as a barred statement under the Code of Criminal Procedure. Such conduct, together with the prompt recovery of the tainted money and surrounding circumstances, provided circumstantial assurance to the direct testimony.

Conclusion: The conduct evidence was admissible and could be relied upon as corroborative material.

Final Conclusion: The conviction was upheld on the whole evidence, and no ground was found for interference in appellate jurisdiction.

Ratio Decidendi: In a trap case, the evidence of a truthful trap witness may by itself sustain conviction, and the accused's conduct on being confronted by the investigating officer is admissible as conduct under the Evidence Act and may corroborate the prosecution case.

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