Chhattisgarh High Court: Bharat Singh Vs Union of India

In a decisive ruling concerning public sector corruption, the High Court of Chhattisgarh has dismissed the second bail application of a Central Goods and Services Tax (CGST) Superintendent. The court emphasized the applicant's active participation in a criminal conspiracy involving a bribe demand of Rs. 34 Lakh and the alleged destruction of digital evidence.

The judgment in the case of Bharat Singh Vs Union of India serves as a stern reminder of the judiciary's zero-tolerance approach towards corruption within revenue departments. The Court distinguished the applicant's role from other co-accused individuals who had been granted bail, noting the gravity of the allegations and the specific acts attributed to the officer during the raid proceedings.

Factual Matrix of the Case

The prosecution's case stems from a complaint lodged by the proprietor of a business establishment, M/s The World of Beauty. The sequence of events, as detailed by the Central Bureau of Investigation (CBI), is as follows:

The Raid and Demand

On 28.01.2025 and 29.01.2025, a team of CGST officers conducted a search and seizure operation (raid) at the business premises of the complainant. The applicant, Bharat Singh, was serving as a Superintendent at CGST, Raipur, and was a key member of this search team.

It is alleged that during and subsequent to the raid, Bharat Singh entered into a criminal conspiracy with a co-accused named Vinay Rai and another individual identified as Mishra (later identified as Anil Kumar Gupta). The objective of this conspiracy was to extract an illegal gratification from the assessee. The accused allegedly demanded a bribe of Rs. 34,00,000 to settle the potential GST liability of the firm. After negotiations, this amount was purportedly reduced to Rs. 10,00,000.

The CBI Trap

Unwilling to succumb to the illicit demand, the complainant approached the Anti-Corruption Branch of the CBI on 30.01.2025. Following a verification of the complaint, the CBI registered a First Information Report (FIR) on 31.01.2025 under Section 61(2) of the Bharatiya Nyaya Sanhita (BNS) and Sections 7 and 7A of the Prevention of Corruption Act, 1988.

A trap was laid by the investigating agency on the same day. The co-accused, Vinay Rai, was apprehended red-handed while accepting an installment of Rs. 5,00,000 at VIP Chowk, Raipur. Subsequent to this apprehension, the CBI arrested Bharat Singh.