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Section 13(1)(e) Prevention of Corruption Act: 12 High Court & Supreme Court Rulings (2025–2026)

A structured research index of 12 High Court and Supreme Court rulings on Section 13(1)(e) of the Prevention of Corruption Act, 1988, covering disproportionate assets prosecutions (2025–2026).

Rangoli Bansal13 min read

This compilation indexes 12 judicial rulings — spanning the Supreme Court of India and multiple High Courts — that engaged Section 13(1)(e) of the Prevention of Corruption Act, 1988 (PC Act) between April 2025 and July 2026. The rulings arise from a range of proceedings: conviction appeals, criminal revision applications, discharge applications, and quashing petitions, covering public servants across government departments and services. The compilation is intended for legal researchers, in-house compliance teams, and anti-corruption practitioners who require a structured, court-wise index of recent case activity on disproportionate assets charges.

Research index only. This page catalogues judicial proceedings for reference purposes. Nothing on this page constitutes legal advice, and readers should verify every ruling against the full text of the judgment before placing reliance on it.


The statutory framework in one paragraph

Section 13(1)(e) of the Prevention of Corruption Act, 1988 defines criminal misconduct by a public servant to include a situation where a public servant, or any person on their behalf, is in possession of, or has, at any time during the period of their office, been in possession of pecuniary resources or property disproportionate to their known sources of income, for which the public servant cannot satisfactorily account. Section 13(2) of the same Act prescribes the punishment for criminal misconduct as defined under Section 13(1), providing for imprisonment and a fine. The offence is typically tried by a Special Court constituted under the PC Act, and prosecution requires prior sanction under the relevant provisions of the Act.


The 12 rulings

1. Ranjit Das vs The Central Bureau Of Investigation

  • Bench: Gauhati High Court
  • Date: 14 July 2026
  • Sections engaged: 13(1)(b), 13(1)(e), 13(2), 19
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The petition (Crl.Pet./1416/2024) was filed before the Gauhati High Court (High Court of Assam, Nagaland, Mizoram and Arunachal Pradesh) and was heard on 25 May 2026, with judgment delivered on 14 July 2026. Per the source preview, the matter was argued before the court with the CBI represented by Standing Counsel and the petitioner represented by counsel; the substantive findings are not available from the source preview.

2. R.Murali vs State Represented By

  • Bench: Madras High Court
  • Date: 3 July 2026
  • Sections engaged: 109, 13(1)(e), 13(2), 20, 374(2)
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: This is a criminal appeal (CRL A No. 37 of 2019) filed before the Madras High Court under Section 374(2) of the Code of Criminal Procedure, praying to set aside the conviction and sentence imposed by the Special Judge cum Chief Judicial Magistrate in Special Case No. 02 of 2008 dated 07.01.2019. Per the source preview, the prosecution's case was that the first accused (a public servant) and the second accused (his wife) acquired assets during the period 01.01.1990 to 31.01.2001; the final findings of the appellate court are not available from the source preview.

3. Major General Anand Kumar Kapur (Retd) vs C B I

  • Bench: Delhi High Court
  • Date: 1 July 2026
  • Sections engaged: 13(1)(e), 13(2), 19
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The appeal (CRL.A. 1099/2016 and CRL.A. 86/2017) was filed before the Delhi High Court challenging the Judgment of Conviction dated 27.09.2016 and Order on Sentence dated 29.09.2016 passed by the learned Special Judge, Patiala House Courts, New Delhi, whereby the appellant was convicted. Per the source preview, the judgment was reserved on 19.02.2026 and pronounced on 01.07.2026; the substantive findings of the High Court are not available from the source preview.

4. S.Murali Mohan, (A-1) vs State By

  • Bench: Madras High Court
  • Date: 17 June 2026
  • Sections engaged: 13(1)(e)
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The petition (CRL OP No. 2245 of 2017) was filed before the Madras High Court seeking to quash F.I.R. No. RC MA 1 2016 A 0045 on the file of the SP/Inspector of Police, CBI, ACB, Chennai. Per the source preview, the court had on 03.07.2025 passed an earlier order directing the Deputy Superintendent of Police, CBI/ACB/Chennai to file a draft final report, and the draft final report was subsequently placed before the court for perusal; the final outcome is not available from the source preview.

5. State vs Sri. V.K.Rajan

  • Bench: Kerala High Court
  • Date: 17 June 2026
  • Sections engaged: 13(1)(e), 13(2)
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: This is a criminal appeal (CRL.A No. 802 of 2024) filed by the State before the Kerala High Court at Ernakulam, against the judgment dated 30.05.2015 in CC No. 44 of 2008 of the Enquiry Commissioner & Special Judge, Thiruvananthapuram. Per the source preview, the respondent/accused was formerly Director of Health Service, Thiruvananthapuram, and the preview references various asset items including ULIP maturity amounts, vehicle loan amounts, and dividend amounts; the final findings of the court are not available from the source preview.

6. Mrudul M. Damle vs Union Of India And Anr

  • Bench: Bombay High Court
  • Date: 11 June 2026
  • Sections engaged: 13(1)(e), 109
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: This Criminal Revision Application (No. 317 of 2015) was filed before the Bombay High Court against the common order of rejection of a discharge application passed by the learned Special Judge for CBI at Thane in Special CBI Case No. 18 of 2012. Per the source preview, the CBI had initially filed an FIR at New Delhi dated 01.02.2005 against the accused and others; the application was reserved on 27 April 2026 and pronounced on 11 June 2026, and the final findings of the court are not available from the source preview.

7. Premjibhai Hirabhai Gohil vs State Of Gujarat

  • Bench: Gujarat High Court
  • Date: 16 April 2026
  • Sections engaged: 13(1)(e), 13(2)
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The appeal (R/Criminal Appeal No. 725 of 2011) was filed before the Gujarat High Court under Section 27 of the Prevention of Corruption Act, 1988 read with Section 374(2) of the Code of Criminal Procedure, 1973, challenging the judgment and order of conviction and sentence dated 30.05.2011 passed by the learned Additional Sessions Judge, Ahmedabad (Rural) Mirzapur, Ahmedabad in Special A.C.B. Case No. 1-2/2005, whereby the appellant-accused was convicted. The final findings of the appellate court are not available from the source preview.

8. (A Petition Under Section 528 Of The ...) vs State Of Odisha .... Opposite Party (S)

  • Bench: Orissa High Court
  • Date: 13 March 2026
  • Sections engaged: 13(2), 13(1)(e), 109
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The petition (CRLMC No. 2624 of 2025) was filed before the Orissa High Court at Cuttack by the petitioner Jharana Sahu, seeking quashing of criminal proceedings in G.R. Case No. 39 of 2012 (Vigilance) arising out of Koraput Vigilance P.S. Case No. 55 of 2012, pending before the Special Judge, Vigilance, Jeypore. Per the source preview, the prosecution case was initiated by Sri Bijay Kumar Malick, Inspector of Police, Vigilance, Koraput Division, Jeypore; the final findings are not available from the source preview.

9. Kumar Raghvendra Singh vs State Of Odisha (Vigilance)

  • Bench: Orissa High Court
  • Date: 12 February 2026
  • Sections engaged: 13(1)(e), 13(2), 239
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The petition (CRLMC No. 2568 of 2024) was filed before the Orissa High Court at Cuttack seeking quashing of the order dated 20.05.2024 passed by the learned Special Judge, Special Court, Bhubaneswar in T.R. No. 01/22 of 2013/2011, whereby an application filed by the petitioner under Section 239 Cr.P.C. seeking discharge was rejected, notwithstanding an earlier remand by the High Court directing fresh consideration of the said application in light of materials available on record. The final findings are not available from the source preview.

10. Amitabh Kumar vs The State Of Bihar Through Economic

  • Bench: Patna High Court
  • Date: 14 July 2025
  • Sections engaged: 13(1)(e)
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The petition (Criminal Miscellaneous No. 49461 of 2023) was filed before the Patna High Court to quash the order dated 17.03.2023 passed in Special Case No. 353 of 2017, arising out of EOU P.S. Case No. 17 of 2017, where the learned Special Judge Vigilance, Patna, took cognizance for the offence under Section 13(1)(e) of the Prevention of Corruption Act, 1988. Per the source preview, the prosecution story appears from the written report of the Dy.S.P. cum Investigating Officer, Economic Offence Unit, Patna; the final findings are not available from the source preview.

11. P. Nallammal vs State By The Inspector Of Police

  • Bench: Supreme Court of India
  • Date: 7 May 2025
  • Sections engaged: 109, 13(1)(e), 13(2)
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: This reportable judgment (2025 INSC 643) arises from Criminal Appeal No. 2489 of 2025 (@ Special Leave Petition (Criminal) No. 2127 of 2024) before the Supreme Court of India, along with connected criminal appeals. Per the source preview, the matter involved Accused No. 2 (P. Nallammal), who had been acquitted by one of the judges on the bench for offences under the relevant sections of the PC Act; the concurring judge recorded that, while agreeing with some observations, he was unable to accept the conclusion and findings of acquittal as regards Accused No. 2, who was the wife of the public servant Accused No. 1, and set out separate reasons accordingly.

12. The State Represented By vs P.Senthamizhselvi

  • Bench: Madras High Court
  • Date: 25 April 2025
  • Sections engaged: 13(1)(e), 239
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: Both criminal revision cases (Crl.R.C. Nos. 258 and 259 of 2013) were filed by the State before the Madras High Court under Section 397 read with Section 401 of Cr.P.C. to set aside the common order passed by the learned Chief Judicial Magistrate, Cuddalore, in Crl.M.P. Nos. 1105 and 1106/2006 in Spl.C.No. 2 of 2006 dated 02.07.2007. Per the source preview, both respondents — P. Senthamizhselvi and M.R.K. Panneerselvam — had been discharged from the case by the learned Chief Judicial Magistrate, and the State challenged those discharge orders; the final findings of the High Court are not available from the source preview.

Patterns across these 12 rulings

  1. Breadth of geographic jurisdiction. The 12 rulings span the Supreme Court of India and seven High Courts — Gauhati, Madras, Delhi, Kerala, Bombay, Gujarat, Orissa, and Patna — indicating that Section 13(1)(e) prosecutions are actively litigated across the entire country, with no single jurisdiction dominating the appellate docket.

  2. Spouse/family member as co-accused. At least three cases in this set (R. Murali vs State — case 2; P. Nallammal vs State — case 11; Premjibhai Hirabhai Gohil vs State — case 7) explicitly involve a spouse or close family member as an accused alongside the public servant, reflecting the typical prosecution pattern under the disproportionate assets provision where assets are held in the name of family members.

  3. Discharge and quashing proceedings as a recurring procedural battleground. Several cases in this compilation arise not from conviction appeals but from petitions seeking discharge or quashing of proceedings at the pre-trial or trial stage (cases 4, 8, 9, 10, 12), indicating that the legality and sufficiency of the prosecution's material are frequently contested before the High Courts.

  4. Companion sections consistently cited alongside 13(1)(e). Across this compilation, Section 13(2) — which prescribes the punishment — appears as a companion provision in the majority of the cases (cases 1, 2, 3, 5, 7, 8, 9, 11). Section 109 of the IPC, addressing abetment, also appears in multiple cases (cases 2, 6, 8, 11), reflecting the standard prosecutorial approach of charging family members or associates with abetment.

  5. Active appellate scrutiny of earlier lower court orders. Multiple rulings (cases 7, 9, 12) arise from challenges to earlier trial court or lower appellate court orders, including remand directions by the High Court for fresh consideration, demonstrating that Section 13(1)(e) cases frequently traverse multiple rounds of judicial scrutiny before final determination.


How to use this compilation

This compilation provides a structured starting point for identifying judicial activity on Section 13(1)(e) of the Prevention of Corruption Act, 1988 across Indian courts for the period April 2025 to July 2026. Researchers should use the case identifiers — court name, case numbers, and dates of judgment as listed — to locate and retrieve the full text of each judgment from official court portals (such as the respective High Court websites, indiankanoon.org, or the Supreme Court of India's website) before drawing conclusions. The source previews available in this index are partial and do not reproduce the final holdings, ratio decidendi, or complete reasoning of any court; reliance on this index alone, without reference to the full judgment, would be methodologically unsound.

Before placing reliance on any ruling, researchers should verify whether the judgment has been subsequently stayed, reversed, or modified by a higher court, and should check whether any Special Leave Petition has been filed or decided in the Supreme Court. Particularly in disproportionate assets cases, the outcome at the High Court level may be subject to further appellate proceedings that post-date this compilation's coverage window. Researchers should also note that procedural outcomes (such as quashing, discharge, or remand) are distinct from acquittals or convictions on the merits, and the two categories carry different legal implications for future proceedings.

This index does not substitute for comprehensive legal research on a specific set of facts. The statutory text of the Prevention of Corruption Act, 1988, including any amendments, and relevant government instructions or circulars (where applicable to the intersection with income-tax or asset-declaration frameworks) should be consulted independently. Practitioners advising on specific matters should also review the applicable Rules and any judicial precedents not covered by this compilation's date range.


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.

RB

Rangoli Bansal

Editorial Reviewer & CA Finalist

CA Finalist (ICAI), B.Com (Hons.) Delhi University. 7+ years across audit, internal controls, SOX 404, ICFR, RCSA, and GRC. Hands-on experience with GST and income-tax compliance filings, statutory audit, and internal audit. Editorial reviewer for TaxNoticeAI's case-law content.

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