This compilation indexes twelve rulings—from the Supreme Court of India, multiple High Courts, and the Income Tax Appellate Tribunal (ITAT)—that engage Section 13(1)(d) across different legal contexts, spanning the period September 2024 to July 2026. The collection is intended as a research starting point for legal professionals, in-house tax and compliance teams, and Big-4 associates who need to quickly locate, cite, and verify primary sources involving this provision. The rulings span criminal appeals, quash petitions, anticipatory bail applications, writ petitions, and income-tax exemption disputes, reflecting the breadth of contexts in which Section 13(1)(d) is invoked in Indian litigation.

Research index only. This page is a structured case-law reference tool, not legal or tax advice. Readers must verify all citations against the full text of each judgment and check for any stays, reversals, or subsequent proceedings before relying on any entry.

The statutory framework in one paragraph

Section 13(1)(d) of the Prevention of Corruption Act, 1988 defines "criminal misconduct" by a public servant. The sub-section, as it stood prior to the Prevention of Corruption (Amendment) Act, 2018, made it an offence for a public servant to, by corrupt or illegal means or by otherwise abusing his position as a public servant, obtain for himself or for any other person any valuable thing or pecuniary advantage. The 2018 amendment restructured the sub-section; the post-amendment provision focuses on the public servant obtaining, for himself or for any other person, any undue advantage without any public interest. The provision is read with Section 13(2), which prescribes punishment, and is frequently charged alongside Section 7 (acceptance of gratification) and Section 120-B of the Indian Penal Code (criminal conspiracy). In the income-tax context, Section 13(1)(d) of the Income Tax Act, 1961 is a separate and distinct provision that restricts the availability of exemption under Sections 11 and 12 to charitable or religious trusts where funds are invested in a manner not conforming to Section 11(5); these are entirely different statutory regimes sharing only a numbering coincidence, and this compilation contains rulings from both contexts as reflected in the source data.

The 12 rulings

1. R. Varadarajan vs Directorate Of Enforcement Rep. By

Bench: Madras High Court
Date: 10 July 2026
Sections engaged: 13(1)(d), 13(2), 43(1), 45(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: This is a criminal original petition filed under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, before the Madras High Court, in which the petitioner (fifth accused) sought to quash the complaint in Spl.C.C.No.1 of 2020 pending before the XIV Additional Sessions Judge for CBI Cases at Chennai. The petition was reserved on 25 June 2026 and pronounced on 10 July 2026; the full outcome of the quash prayer is not specified in the source preview.

2. Chitra Ramkrishna vs Union Of India & Anr

Bench: Delhi High Court
Date: 9 July 2026
Sections engaged: 120B, 13(1)(d), 13(2), 19, 2(c), 43, 66
Outcome: Outcome not specified in source
Procedural / substantive ground: The present writ petition was filed under Articles 226 and 227 of the Constitution of India read with Section 482 of the Code of Criminal Procedure, 1973 before the Delhi High Court. The factual background, per the source preview, relates to M/s National Stock Exchange of India; the petition (W.P.(CRL) 3343/2023) was reserved on 26 May 2026 and pronounced on 9 July 2026. The full outcome is not specified in the source preview.

3. DCIT(E) Circle-1(1) New Delhi, Delhi vs Indian Broadcasting Foundation, Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 8 July 2026
Sections engaged: 11(5), 11(5)(vii), 12A, 13(1)(d), 25
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No.5626/Del/2025) relates to Assessment Year 2017-18 and was filed by the Revenue before the ITAT Delhi Bench. The assessee, Indian Broadcasting Foundation (PAN: AAACI7146J), is a not-for-profit company registered under Section 12A of the Income Tax Act, 1961, incorporated as an association of broadcasters, and had claimed exemption under Sections 11 and 12 in its return of income; the Revenue raised grounds under Section 13(1)(d) of the Income Tax Act relating to investment of funds, and the full outcome of this appeal is not specified in the source preview.

4. Sardar Sarfaraz Khan vs State By Lokayukta Police

Bench: Karnataka High Court
Date: 1 July 2026
Sections engaged: 13(1)(b), 13(1)(d), 13(2), 17, 185
Outcome: Outcome not specified in source
Procedural / substantive ground: This writ petition (W.P. No.4307 of 2026) was filed under Articles 226 and 227 of the Constitution of India read with Section 528 of the BNSS, 2023, before the Karnataka High Court, seeking to quash FIR in Crime No.63/2025 dated 23 December 2025 registered by the Karnataka Lokayukta Police for alleged offences under Sections 13(1)(b) read with Section 13(2) of the Prevention of Corruption Act, 1988, with the matter pending before the XXIII Additional City Civil and Sessions Judge, Special Court, Bengaluru. The petition was reserved on 25 April 2026 and pronounced on 1 July 2026; the outcome of the quash prayer is not specified in the source preview.

5. Dr. Ashok Kumar Singh vs The Central Bureau Of Investigation

Bench: Jharkhand High Court
Date: 12 June 2026
Sections engaged: 13(1)(a), 13(1)(d)
Outcome: Outcome not specified in source
Procedural / substantive ground: This is an anticipatory bail application (A.B.A. No.1609 of 2026) filed before the Jharkhand High Court. Per the source preview, the petitioner was apprehending arrest in connection with CBI/SPE/ACB Dhanbad FIR No. RC 4(A)/2023D, registered for offences under Section 13(2) read with Section 13(1)(d) and Section 13(2) read with Section 13(1)(a) of the Prevention of Corruption Act, 1988 (as amended in 2018), with the matter pending before the learned ADJ-III-cum-Special Judge, CBI, Dhanbad. The petitioner was described in the source preview as having been posted as Chief Scientist from 2017 to 2025 and Head of Research Group, CSIR-CIMFR; the outcome of the anticipatory bail application is not specified in the source preview.

6. S.Arivarasu vs State Rep. By

Bench: Madras High Court
Date: 9 June 2026
Sections engaged: 13(1)(d)
Outcome: Outcome not specified in source
Procedural / substantive ground: These are criminal appeals (Crl.A.Nos.633, 650 & 652 of 2019) filed under Section 374(2) of the Code of Criminal Procedure, seeking to set aside the judgment and sentence passed by the II Additional District Judge (CBI Cases), Coimbatore in C.C.No.8 of 2011 dated 28 August 2019. The appeals were reserved on 18 February 2026 and pronounced on 9 June 2026; the CBI matter arose from R.C.No.6(2)/2010, and the full outcome of the criminal appeals is not specified in the source preview.

7. Sunil Kumar vs State

Bench: Delhi High Court
Date: 14 May 2026
Sections engaged: 13(1)(d)
Outcome: Outcome not specified in source
Procedural / substantive ground: This criminal appeal (CRL.A. 179/2004) was filed under Section 374(2) of the Code of Criminal Procedure, 1973, before the Delhi High Court. Per the source preview, the sole accused in C.C. No.117/1994 challenged the judgment dated 09.02.2004 and order on sentence dated 13.02.2004 of the Special Judge, Delhi, by which he was convicted and sentenced for offences under Sections 7 and 13(2) read with Section 13(1)(d) of the Prevention of Corruption Act, 1988; the prosecution case related to alleged demand and acceptance of ₹1,500/- from PW4 for installation of an electricity meter, while the accused was working as Inspector DESU, Zonal Office, Sector-III, Rohini, Delhi. The full outcome of this appeal is not specified in the source preview.

8. Jalaj Batra vs Central Bureau Of Investigation

Bench: Delhi High Court
Date: 4 May 2026
Sections engaged: 13(1)(d), 32A
Outcome: Outcome not specified in source
Procedural / substantive ground: This petition (CRL.M.C. 682/2025) was filed before the Delhi High Court, wherein the petitioner (shown as A-2 in a supplementary charge-sheet filed against 34 accused persons) challenged the order dated 27 April 2024 by which the Trial Court (Special Judge (PC Act), CBI-08, Rouse Avenue Court, New Delhi) took cognizance and summoned the accused. Per the source preview, the FIR (RC No. 2242022A0001) was registered on 20 June 2022 on a complaint by the Deputy General Manager, Union Bank of India, and the allegations involved a criminal conspiracy to cheat a Consortium of 17 Banks led by Union Bank of India. The full outcome of this petition is not specified in the source preview.

9. Aman Bhatia vs State(Gnct Of Delhi)

Bench: Supreme Court of India
Date: 2 May 2025
Sections engaged: 13(1)(d), 2(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: This is a reportable judgment of the Supreme Court of India in Criminal Appeal No.2613 of 2014 (citation: 2025 INSC 618). Per the source preview, a trap was laid by the ACB following a complaint; the complainant was handed currency notes smeared with phenolphthalein powder by the Raid Officer, and the appellant, while working as Sub-Registrar at Janakpuri, Delhi, allegedly demanded and accepted ₹12/- from the complainant. Upon completion of investigation, charges were framed by the Special Judge (Anti-Corruption Branch), Delhi for offences under Sections 7 and 13(1)(d) read with Section 13(2) of the PC Act; the full outcome of the Supreme Court's decision is not specified in the source preview.

10. Chedilal Jaiswal vs State Of Chhattisgarh

Bench: Chattisgarh High Court
Date: 21 March 2025
Sections engaged: 13(1)(d), 13(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This criminal revision (CRR No.841 of 2018, citation: 2025:CGHC:13744) was filed before the High Court of Chhattisgarh at Bilaspur against the order dated 27 June 2018 passed by the learned Special Judge (Prevention of Corruption Act), Balrampur at Ramanujganj in Special Criminal Case-1 of 2017, whereby the trial court framed the charge against the applicant for the offence under Section 13(2) of the Prevention of Corruption Act, 1988 and Section 120-B of the IPC. The order was reserved on 7 January 2025 and delivered on 21 March 2025; the outcome of the revision is not specified in the source preview.

11. Kansari Behera vs State Of Odisha

Bench: Orissa High Court
Date: 9 October 2024
Sections engaged: 13(1)(d), 13(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This writ petition (W.P.(C) No.28593 of 2022) was filed before the Orissa High Court at Cuttack under Articles 226 and 227 of the Constitution of India. Per the source preview, the petitioner sought relief relating to the treatment of periods of suspension from 30.09.2000 to 30.09.2013 and consequential fixation of pay on a notional basis, with the respondents including the State of Odisha, the Revenue Divisional Commissioner (Southern Division), and the Collector & District Magistrate, Kandhamal; the full outcome of this petition is not specified in the source preview.

12. ITO, Ward (Exemption), Jodhpur vs Rajasthan Vikas Sansthan , Jodhpur

Bench: Income Tax Appellate Tribunal - Jodhpur
Date: 26 September 2024
Sections engaged: 13(1)(c), 13(1)(d)
Outcome: Outcome not specified in source
Procedural / substantive ground: These are two appeals (ITA Nos.77 & 78/Jodh/2024) filed by the Income Tax Officer, Ward (Exemption), Jodhpur before the ITAT Jodhpur Bench for Assessment Years 2016-17 and 2017-18, against the appellate order of the National Faceless Appeal Centre (NFAC), Delhi dated 15.12.2023; the NFAC had partly allowed the assessee's (Rajasthan Vikas Sansthan, PAN: AAATR3975P) appeal against assessment orders passed under Section 143(3) of the Income Tax Act, 1961 by ITO-Exemption Circle, Jodhpur dated 22.08.2019 and 23.12.2019 respectively, with the Revenue aggrieved on similar grounds across both years. The full outcome of these appeals is not specified in the source preview.

Patterns across these 12 rulings

Dominance of the Prevention of Corruption Act context. The large majority of the twelve rulings (cases 1, 2, 4, 5, 6, 7, 8, 9, 10, 11) engage Section 13(1)(d) in the context of the Prevention of Corruption Act, 1988, not the Income Tax Act, 1961. Only cases 3 and 12 arise from the income-tax exemption regime. Researchers must carefully distinguish which statutory version of Section 13(1)(d) is engaged before applying any ruling.
Frequent co-citation of Section 13(2) PC Act. Across multiple rulings in this set (cases 1, 2, 4, 5, 10, 11), Section 13(1)(d) is cited together with Section 13(2) of the Prevention of Corruption Act, which prescribes punishment. This consistent pairing is a standard prosecutorial and pleading pattern and appears across different High Courts and different fact situations in this compilation.
Diversity of procedural vehicles. The rulings reach the courts through a wide range of procedural mechanisms — quash petitions under BNSS Section 528, anticipatory bail applications, criminal appeals under Section 374(2) CrPC, writ petitions under Articles 226 and 227, criminal revisions, and ITAT appeals. This reflects that Section 13(1)(d) (whether under the PC Act or the IT Act) is litigated at every stage from bail to final appeal.
High Court geographic spread. The twelve rulings span the Madras High Court (cases 1 and 6), Delhi High Court (cases 2, 7, and 8), Karnataka High Court (case 4), Jharkhand High Court (case 5), Chhattisgarh High Court (case 10), and Orissa High Court (case 11), in addition to the Supreme Court (case 9) and ITAT benches at Delhi (case 3) and Jodhpur (case 12). This geographic spread indicates that litigation involving Section 13(1)(d) is not concentrated in any single jurisdiction.
Outcomes uniformly unspecified in the source data. For all twelve cases in this compilation, the outcome direction is recorded as "Outcome not specified in source." Researchers relying on this index must access the full text of each judgment from the source portals to ascertain the actual holding, relief granted or refused, and the reasoning of the court before drawing any conclusion about the direction of judicial trend.

How to use this compilation

This index is organised to help researchers rapidly identify relevant precedents by bench, date, and sections engaged. Each entry provides the case identity fields verbatim from the structured corpus and a brief procedural note drawn from the source preview. To move from this index to substantive research, the recommended workflow is: (1) note the case name, court, and date from the heading fields; (2) locate the full text of the judgment on the official court portal (e.g., indiankanoon.org, the High Court's own JUDIS portal, or the Supreme Court's official website); and (3) read the complete reasoning, operative order, and any directions before drawing conclusions about the court's holding.

Researchers should also verify whether any of these orders have been stayed, reversed, or modified in subsequent proceedings. Interlocutory orders (such as anticipatory bail decisions and orders on framing of charge) may have been superseded by final judgments, and appellate orders may have been challenged further. The Prevention of Corruption Act was substantively amended in 2018, and the applicability of the pre-amendment versus post-amendment version of Section 13(1)(d) can be determinative in individual cases; this compilation does not assess which version applied in each case, and researchers must verify this from the full judgment text.

For ITAT rulings in the income-tax exemption context (cases 3 and 12 in this compilation), researchers should additionally check for any corresponding High Court or Supreme Court proceedings arising from those ITAT orders, any CBDT circulars or instructions that may be relevant, and whether the assessee's registration status under the relevant provisions of the Income Tax Act has changed in the intervening period.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 13(1)(d) Prevention of Corruption Act: 12 Court Rulings (2024–2026)