Departmental exoneration does not bar corruption prosecution where statutory presumptions and criminal proof requirements remain distinct.

Exoneration in departmental proceedings does not automatically bar criminal prosecution on the same factual foundation, particularly where the criminal case is governed by the Prevention of Corruption Act, 1988 and its statutory presumptions. The Court distinguished the limited evidentiary scope of a domestic inquiry from the requirements of criminal proof, and held that acceptance of the inquiry report did not by itself render the prosecution case untenable. It also found that the cited precedent did not compel quashing of the FIRs or criminal proceedings on the facts presented, and that conviction could not be treated as wholly unlikely merely because the departmental authority had exonerated the petitioners.

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Issues: Whether exoneration of the petitioners in departmental proceedings on the same factual foundation barred continuation of the criminal prosecution under the Prevention of Corruption Act, 1988 and the Code of Criminal Procedure, 1973.

Analysis: The departmental enquiry proceeded on the limited evidence adduced in the domestic inquiry and culminated in exoneration on merits. The criminal case, however, rested on allegations under the Prevention of Corruption Act, 1988, where the statutory scheme includes a presumption against a public servant on proof of foundational facts. The Court distinguished the departmental findings from the criminal prosecution, held that the earlier exoneration did not by itself negate the prosecution case, and found that the cited precedent did not compel quashing of the FIRs or criminal proceedings in the present facts. The Court further held that the chances of conviction could not be said to be totally bleak merely because the departmental authority had accepted the inquiry report.

Conclusion: The criminal prosecution was not liable to be quashed on the ground of departmental exoneration, and the petitioners were not entitled to relief.

Ratio Decidendi: Exoneration in departmental proceedings does not ipso facto bar criminal prosecution on the same facts, particularly where the criminal case is governed by the statutory presumptions and evidentiary requirements of the Prevention of Corruption Act, 1988.

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