Karnataka High Court
Ananya Manohar vs State By Karnataka Lokayukta Police on 25 September, 2025
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NC: 2025:KHC:38911
CRL.P No. 12602 of 2025
HC-KAR
IN THE HIGH COURT OF KARNATAKA AT BENGALURU
DATED THIS THE 25TH DAY OF SEPTEMBER, 2025
BEFORE
THE HON'BLE MR. JUSTICE SACHIN SHANKAR MAGADUM
CRIMINAL PETITION NO. 12602 OF 2025
BETWEEN:
1. ANANYA MANOHAR
AGED ABOUT 31 YEARS
W/O PRAVEEN KUMAR AND
D/O H. MANOHARA
WORKING AS ASSISTANT DIRECTOR
OFFICE OF THE ASSISTANT DIRECTOR,
DEPARTMENT OF TOWN AND
COUNTRY PLANNING, MANDYA
RESIDING AT LIG 38, 2ND STAGE
HOUSING BOARD
SADVIDYA CHILDREN'S SCHOOL BACKSIDE
MANDYA-571401.
...PETITIONER
(BY SRI. P.S. RAJAGOPAL, SENIOR ADVOCATE FOR
SMT. ASHWINI RAJAGOPAL, ADVOCATE)
Digitally signed
by AL BHAGYA
Location: HIGH
COURT OF AND:
KARNATAKA
1. STATE BY KARNATAKA LOKAYUKTA POLICE
REP. BY POLICE INSPECTOR
MANDYA DIVISION
MANDYA-571401.
...RESPONDENT
(BY SRI. K. PRASANNA SHETTY, ADVOCATE)
THIS CRL.P FILED U/S 482 CR.PC (FILED U/S 528 BNSS)
PRAYING TO QUASH FIR DATED 21.07.2025 (UNDER
ANNEXURE A TO THIS PETITION) FOR O/U/S 7(a) OF THE
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NC: 2025:KHC:38911
CRL.P No. 12602 of 2025
HC-KAR
PREVENTION OF CORRUPTION ACT, 1988, REGISTERED BY THE
LOKAYUKTA P.S, MANDYA AGAINST THE PETITIONER IN
CR.NO.06/2025 BEFORE THE COURT OF THE PRL.DIST. AND
SESSIONS JUDGE, MANDYA, IN SO FAR AS THE PETITIONER IS
CONCERNED AND ALL FURTHER PROCEEDINGS TAKEN
PURSUANT THERETO, AND GRANT ALL CONSEQUENTIAL
RELIEFS.
THIS PETITION, COMING ON FOR DICTATING ORDERS,
THIS DAY, ORDER WAS MADE THEREIN AS UNDER:
CORAM: HON'BLE MR. JUSTICE SACHIN SHANKAR MAGADUM
ORAL ORDER
This petition is filed by accused No.1 seeking quashing of the proceedings pending in Crime No.06/2025 for the offence punishable under Section 7(a) of the Prevention of Corruption Act, 1988, registered by the respondent/Lokayukta.
2. The gist of the complaint, which culminated in registration of the present crime, is that the petitioner along with other co-accused were deliberately delaying the approval process of a single plot layout and, in that context, were allegedly demanding a bribe of Rs.30,000/- for facilitating the said work. Acting upon directions, the -3- NC: 2025:KHC:38911 CRL.P No. 12602 of 2025 HC-KAR Mandya Lokayukta Police registered Crime No.06/2025 against the petitioner and other accused, including the Assistant Director of Land Records (ADLR). Pursuant thereto, a trap was conducted on 22.07.2025 in the office of the Assistant Director, Department of Town and Country Planning, whereafter the petitioner and two others were taken into custody and remanded to judicial custody. The petitioner now stands accused of an offence under Section 7(a) of the Prevention of Corruption Act, 1988.
3. This petition is filed seeking to challenge the registration of crime insofar as the petitioner is concerned. Placing reliance on the judgment of the Hon'ble Apex Court in Satish Mehra vs. NCT of Delhi1, learned Senior Counsel contends that neither the FIR nor the criminal complaint discloses any triable offence against the petitioner. It is therefore urged that this Court, in exercise of its inherent jurisdiction under Section 482 of the Code of Criminal Procedure, ought to interdict the proceedings. 1 AIR 2013 SC 506 -4- NC: 2025:KHC:38911 CRL.P No. 12602 of 2025 HC-KAR
4. Reliance is also placed on the celebrated judgment of the Hon'ble Supreme Court in State of Haryana vs. Bhajan Lal2, wherein the categories of cases warranting quashing of proceedings have been delineated. It is contended that the allegations in the FIR, even if taken at their face value and accepted in entirety, do not prima facie disclose commission of any offence by the petitioner. The subsequent evidence collected during investigation, it is urged, equally fails to establish the essential ingredients of the alleged offence. If the proceedings are permitted to continue, it is argued, the same would amount to sheer abuse of process. Learned counsel has further drawn support from the decision in R.P. Kapur vs. State of Punjab3, to contend that the investigating agency has proceeded to collect material even prior to registration of the FIR, thereby vitiating the process.
2 (1992) Supp (1) SCC 335 3 AIR 1960 SC 866 -5- NC: 2025:KHC:38911 CRL.P No. 12602 of 2025 HC-KAR
5. Learned Senior Counsel, reiterating the above grounds, submits that there is no material to indicate that the petitioner either demanded or accepted any gratification. Particularly reliance is placed on the recorded conversations between the complainant and the petitioner, which, it is asserted, do not establish any demand. Since demand and acceptance are the sine qua non for attracting Section 7(a) of the Act, absence of such material ought to enure to the petitioner's benefit. Learned Senior Counsel further submits that the petitioner had already discharged his official obligations and, once the matter was forwarded to the ADLR for land survey pre- condition for approval of single-plot layouts, nothing remained pending at the petitioner's end. Notwithstanding this, the petitioner is sought to be falsely implicated although the file itself was pending with the ADLR for more than seven months.
6. Per contra, learned counsel for the respondent/Lokayukta, drawing attention to the call -6- NC: 2025:KHC:38911 CRL.P No. 12602 of 2025 HC-KAR records, submits that sufficient material has emerged against the petitioner, who is shown to have actively participated in the transaction. It is contended that the telephonic conversations between the petitioner and the complainant clearly reveal reference to illegal gratification. The learned counsel further points out that the FSL report is awaited and investigation cannot be curtailed at this premature stage. It is therefore urged that the petition be dismissed as not maintainable.
7. Having heard the rival submissions and on perusal of the record, this Court has bestowed its anxious consideration on the grounds urged by the petitioner and the material placed on record.
8. Though there exists a catena of judgments indicating that, unless a trap is successfully conducted, the ingredients of Section 7(a) of the Prevention of Corruption Act, 1988 may not be attracted, the latest developments, particularly the law laid down by the Hon'ble Apex Court -7- NC: 2025:KHC:38911 CRL.P No. 12602 of 2025 HC-KAR in Devinder Kumar Bansal vs. State of Punjab4, must be noted. The Hon'ble Apex Court, while examining the scope and ambit of Section 7(a), has held that even an attempt by a public servant to demand a bribe constitutes an offence. It is sufficient if there are prima facie materials indicating an attempt to demand gratification, and such determination is a matter to be adjudicated during trial. In such circumstances, no indulgence can be extended by this Court at the threshold.
9. The submission of the petitioner that immediately upon receipt of the application seeking single plot approval, he referred the matter to the ADLR for conducting a survey and forwarding the report for further action cannot be accepted at this stage. As rightly pointed out by the learned counsel for the respondent, the telephonic conversations between the complainant and the petitioner, who is arraigned as accused No.1, prima facie indicate a case warranting investigation. Whether the 4 2025 INSC 320 -8- NC: 2025:KHC:38911 CRL.P No. 12602 of 2025 HC-KAR alleged demand for gratification was made jointly by the petitioner and accused No.2, or whether the demand made by accused No.2 was on behalf of the petitioner, is a matter that can only be determined through a detailed investigation.
10. A perusal of the call records placed on record shows that there were communications between the petitioner/accused No.1 and the complainant. Although the call records are in the vernacular language, they provide sufficient prima facie indication of involvement, warranting further investigation.
11. Learned Special Counsel has correctly pointed out that the investigation is still ongoing and crucial materials, including the FSL report, are awaited. On careful consideration of the complaint and the materials furnished by the petitioner himself, this Court is of the considered view that the investigation is still at a nascent stage. The offences alleged under the Prevention of -9- NC: 2025:KHC:38911 CRL.P No. 12602 of 2025 HC-KAR Corruption Act are serious in nature. Whether the petitioner/accused No.1 actively participated in demanding the bribe, or merely processed the file and had no role once it was forwarded to the ADLR, is a matter that requires thorough investigation.
12. In this context, the Court finds merit in the submission made by the learned Special Counsel that the call detail records and other investigative materials require careful evaluation before any final opinion regarding the petitioner's culpability can be formed.
13. In view of the foregoing, the Court is of the firm opinion that the prayer of the petitioner/accused No.1 seeking quashing of the proceedings at this stage cannot be acceded to.
14. The judgment relied upon by learned Senior Counsel, rendered by the coordinate Bench in Crl.P. No.15461/2011, is inapplicable to the present facts. That judgment dates back to 2011, and the law on this subject
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NC: 2025:KHC:38911 CRL.P No. 12602 of 2025 HC-KAR has since evolved. The recent judgment of the Hon'ble Apex Court in Devinder Kumar Bansal (supra) squarely addresses the issue, clarifying that even an attempt to secure illegal gratification constitutes an offence. In this light, the investigating agency must be permitted to conclude the investigation. Should any adverse report be filed, the petitioner remains at liberty to challenge it in accordance with law.
15. Accordingly, the petition stands dismissed.
Sd/-
(SACHIN SHANKAR MAGADUM) JUDGE CA List No.: 1 Sl No.: 60