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Conviction under Section 161 IPC and Section 5(2) of Prevention of Corruption Act, 1947 for receiving illegal gratification. Analysis: The appellant, a Sub-Registrar, was convicted for receiving Rs. 60 as illegal gratification from a complainant. The High Court confirmed the conviction and sentence, which the appellant challenged. The appellant's defense was that he received the amount as advance money as per the rules in force. However, the trial Judge and the High Court rejected this defense and relied on the legal presumption under Section 4(1) of the Prevention of Corruption Act, 1947. The legal presumption under Section 4(1) of the Act shifts the burden to the accused to prove that the gratification was not accepted as a motive or reward for official work. The prosecution must first prove that the amount received was gratification, meaning acceptance to the pleasure or satisfaction of the recipient. If the money was not for personal satisfaction, the presumption under Section 4(1) cannot be applied. The crucial question is whether the amount paid was for the personal satisfaction of the appellant. The appellant argued that the Courts failed to consider certain probabilities, such as the rules governing issuance of certified copies and the lack of awareness of charges by the complainant. The evidence showed that the appellant followed the procedures outlined in the Maharashtra Registration Manual for collecting fees for copies. Had the appellant made proper entries and issued a receipt, there would have been no basis to claim the amount was illegal gratification. The High Court's reasons for rejecting the appellant's plea were scrutinized. The lack of explicit mention of "advance," keeping the money in the pocket, and not issuing a receipt were not conclusive evidence against the appellant. The evidence suggested that the appellant's actions were in line with legal requirements, and there was not enough time for formalities due to the swift intervention of the anti-corruption squad. Considering the doubts raised by the evidence and the appellant's consistent defense, the Supreme Court acquitted the appellant of the charges, overturning the conviction and sentence. The Court extended the benefit of doubt to the appellant, emphasizing the importance of fair consideration in such cases.
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