The pursuit of a small tax refund turned into a decade-long legal battle for an income tax official in Bihar. In a stern reminder that the law does not measure the “size” of corruption by the amount of money involved, the Patna High Court recently upheld the conviction of a Tax Assistant who was caught red-handed accepting a bribe of just ₹600.
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ToggleCase Background
The roots of this case date back to the financial year 2008-2009. The complainant, a taxpayer, had filed for a refund of ₹5,826—an amount deducted as tax from his commissions.
Despite multiple visits to the Income Tax Office in Sasaram, the refund remained stalled. It was alleged that Ram Narayan Singh, then serving as a Tax Assistant, demanded a “commission” of 10% of the refund amount (approximately ₹600) to process the file.
The CBI Trap
Unwilling to pay the graft, the complainant approached the Central Bureau of Investigation (CBI). A trap was laid, and on the designated day, the CBI caught Singh red-handed while he was accepting the tainted currency notes.
Trial and Sentencing
The Special Judge (CBI) in Patna originally found Singh guilty under the Prevention of Corruption Act, 1988.
Conviction: Sections 7 and 13(2) read with 13(1)(d) of the PC Act.
Sentence: One year of Rigorous Imprisonment (RI) and a monetary fine.
High Court Proceedings (December 2025)
The official challenged the trial court’s verdict in the Patna High Court, arguing that the evidence was insufficient and the amount was trivial. However, Justice Alok Kumar Pandey dismissed the appeal on December 22, 2025.
Key Observations by the Court:
”When a government employee demands and accepts a bribe, and this is proven through a CBI sting and independent evidence, the integrity of the public office is compromised regardless of the amount.”
The Court highlighted that the prosecution had proved the demand, acceptance, and recovery of the bribe beyond a reasonable doubt. Consequently, the High Court cancelled his bail bonds and ordered him to surrender immediately to serve his jail term.
Case Summary at a Glance
| Feature | Details |
|---|---|
| Accused | Ram Narayan Singh (Tax Assistant) |
| Bribe Amount | ₹600 |
| Original Refund Claim | ₹5,826 |
| Investigating Agency | CBI (Central Bureau of Investigation) |
| Final Verdict | 1-Year Rigorous Imprisonment Upheld |
| Court | Patna High Court |
Why This Judgment Matters
This ruling serves as a significant precedent in Indian administrative law for several reasons:
Zero Tolerance Policy: It reinforces the “Zero Tolerance” stance towards corruption. The judiciary is sending a clear message: even a small bribe is a criminal breach of trust.
Presumption of Guilt: Under the PC Act, once the recovery of money is proven, the burden of proof often shifts to the accused to explain that the money was not a bribe.
Public Accountability: It empowers common citizens to report even small-scale harassment by government officials, knowing that the law will take its course.
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