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Issues Involved:
1. Validity of the sanction for prosecution under Section 6 of the Prevention of Corruption Act. 2. High Court's approach to setting aside an acquittal. Detailed Analysis: 1. Validity of the Sanction for Prosecution: The first contention raised by the appellant was the absence of a proper or valid sanction for prosecution as required under Section 6 of the Prevention of Corruption Act. The prosecution relied on a letter (Ex. P-10) from the Excise Commissioner, U.P., to the Collector of Meerut, which purportedly sanctioned the prosecution. The appellant argued that the sanction was invalid because it was signed by the Personal Assistant to the Excise Commissioner, not the Commissioner himself, and there was no evidence that the material facts constituting the offense were placed before the sanctioning authority. The court found that while the letter was signed by the Personal Assistant, the draft of the letter (Ex. P-11) contained the Excise Commissioner's signature below the word "approved." Although this method of according sanction was not ideal, the court accepted that the sanction was given by the Excise Commissioner. However, the court agreed with the appellant that the prosecution failed to prove that the material facts were placed before the sanctioning authority. The witness, Mr. Dikshit, refused to show the details sent to the Excise Commissioner, thereby withholding crucial evidence. Consequently, the sanction was deemed defective, rendering the initiation of proceedings illegal and without jurisdiction. 2. High Court's Approach to Setting Aside an Acquittal: The second contention was that the High Court did not adhere to the principles guiding appellate courts in setting aside an acquittal. The trial Magistrate had acquitted the accused based on a thorough evaluation of the evidence, but the High Court reversed this decision. The Supreme Court emphasized that the High Court must give proper weight to the trial court's views on witness credibility, the presumption of innocence, the right of the accused to benefit from any doubt, and the advantage the trial judge has in seeing the witnesses. The High Court failed to observe these principles and did not adequately consider the material facts and findings of the trial court. The trial Magistrate found no credible evidence to support the complainant's story that the accused demanded or accepted a bribe. The complainant's statements were inconsistent, and the evidence suggested that the accused knew Mr. Burney, the Magistrate involved in the trap, making it improbable that he would accept a bribe in his presence. The High Court dismissed these findings without sufficient justification, leading to a misappreciation of the evidence. The Supreme Court concluded that the High Court's judgment was unsupportable and reinstated the trial Magistrate's acquittal. Conclusion: The Supreme Court set aside the High Court's judgment and restored the trial Magistrate's acquittal, highlighting the importance of a valid sanction for prosecution and the proper approach appellate courts must take when reviewing acquittals.
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