A Step Towards Fighting Corruption - The Case Of Neeraj Dutt V. State (Govt. Of Delhi NCT)

Author: LawSphereX

Category: International Law

Published: 2026-08-23T17:21:11.333132+00:00

Updated: 2026-08-26T17:12:35.593+00:00

A STEP TOWARDS FIGHTING CORRUPTION: THE CASE

OF NEERAJ DUTT V. STATE (GOVT. OF DELHI NCT)

Shazia Khatoon, The West Bengal National Law University of Juridical Sciences

ABSTRACT

Corruption is a cancer: a cancer that eats away at a citizen's faith in democracy, diminishes the instinct for innovation and creativity; alreadytight national budgets, crowding out important national investments. It wastes the talent of entire generations. It scares away investments and jobs. 1Corruption remains one of the biggest challenges in governance and law enforcement. This paper analyzes how circumstantial evidence plays a crucial role in convicting individuals accused of corruption. Using Neeraj Dutt v. State (Govt. of Delhi NCT) (2022) as a case study, this paper examines how courts interpret indirect evidence in bribery and financial crime cases. Additionally, the research expands on other notable corruption cases, including the 2G Spectrum Scam, Coal Scam and Commonwealth Games Scam, to illustrate how circumstantial evidence is utilized in legal proceedings.

This paper also explores various criminological theories, such as Routine Activity Theory, Strain Theory, and Institutional Anomie Theory, to explain why corruption thrives in certain environments. Furthermore, legal reforms, policy changes, and technological advancements such as digital forensics and whistleblower protection laws are discussed as mechanisms to strengthen anti-corruption frameworks. This article sheds light on the importance of circumstantial evidence, types of clues & tell-tale signs, its admissibility, and probative value. The paper discusses circumstantial evidence in bribery cases. It focuses on Neeraj Dutt v. State (Govt. of Delhi)

2022. The role of circumstantial evidence in convictions is analyzed. The

court's interpretation of evidence standards is highlighted. Keywords: Corruption, Circumstantial Evidence, Bribery, White Collar Crime, Criminological theories.

1 https://www.brainyquote.com/quotes/joe_biden_676835?src=t_corruption

INTRODUCTION

Corruption in India has a long history, dating back to ancient times with texts like Kautilya's Arthashastra2. It persisted during Mughal rule, British colonial rule3, and post-independence, with legal reforms like the Lokpal and Lokayukta Act 2013 and the Prevention of Corruption (Amendment) Act 2018 aimed at curbing corruption. 4 Corruption in India is a significant issue affecting governance, public administration, and economic development. It involves misuse of public office for private gain through bribery, nepotism, fraud, and embezzlement. It can be classified into political, bureaucratic, and corporate corruption, each affecting system efficiency and integrity. The Prevention of Corruption Act 1988 primarily regulates India's corruption, which criminalizes bribery and misuse of official positions.

The Prevention of Corruption (Amendment) Act 2018 introduced stricter provisions, and the Lokpal and Lokayuktas Act

2013 established independent anti-corruption bodies for high-level corruption investigations.

Corruption in India, dating back to ancient texts, has been institutionalized during the British colonial period and continues to grow post-independence due to economic liberalization, political influence, and weak enforcement mechanisms. Transparency International's Corruption Perception Index ranks India5 among countries struggling with corruption, highlighting systemic governance and law enforcement loopholes. Corruption is the misuse of power for personal gain, including bribery, embezzlement, nepotism, fraud, favoritism, and misuse of public office. It is not limited to financial misconduct but also includes unethical behavior that undermines justice, transparency, and accountability in governance. In India, corruption is regulated under the Prevention of Corruption Act 19886, which criminalizes offenses such as bribery, criminal misconduct, and influence peddling. The

2 R Shamasastry (tr), Kautilya’s Arthashastra (Bangalore Government Press 1915).

3 Partha Gupta, The British Impact on India’s Administrative System (Oxford University Press 2011).

4 PRS Legislative Research, The Lokpal and Lokayuktas Act 2013 https://prsindia.org accessed 28 February 2025. 5 Transparency International, Corruption Perceptions Index 2023 https://www.transparency.org accessed 28 February 2025. 6 Government of India, The Prevention of Corruption Act 1988 https://indiacode.nic.in accessed 28 February

Prevention of Corruption (Amendment) Act 20187 introduced stricter provisions, including punishment for bribery, time-bound trials, and forfeiture of property acquired through corrupt means. The Indian Penal Code (IPC), 1860, and the Lokpal and Lokayuktas Act 2013 supplement the legal framework to address corruption. National and international regulations, such as the United Nations Convention Against Corruption (2003)8, the Convention on the Combating of Bribery of Foreign Public Officials in International Business Transactions (1997)9, the FATF Recommendations10, and the Council of Europe’s Criminal Law Convention on Corruption (1999)11, advocate for the need to apply varied means of proof, including imputed evidence, in the investigation of financial crimes such as corruption, bribery, and money laundering.

These conventions accept that these crimes are often hidden away, making it difficult to get concrete evidence, and do promote targets as offenders on the basis of evidence such as financial movements, people’s sayings, and behaviors. In criminology, attached communication correlates people’s involvement in criminal acts thus facilitating the prosecution of crimes such as economic crime without any material evidence present. The Indian Penal Code (IPC) 186012, was passed at the time when India was a British colony, and appropriately so, formed the basis of laws to deal with various crimes, which also included economic offenses such as fraud and embezzlement. The conviction rate, however, depended mainly on direct evidence. This denotes the absence of advanced methods of investigation. Circumstantial evidence was not given much importance during this period.

It was after the enactments of the Indian Evidence Act of 187213 that a law for the admission of circumstantial evidence was found. Sections 3 and 114 of the Act permitted the courts to draw conclusions from facts that are inter-related, thus appreciating the evidence of circumstances even in matters 7 Government of India, Prevention of Corruption (Amendment) Act 2018 https://indiacode. nic. in accessed 28 February 2025.

8 United Nations Convention against Corruption (UNCAC), GA Res 58/4, UN Doc A/RES/58/4 (31 October

2003) https://www.unodc.org/unodc/en/corruption/convention.html accessed 28 February 2025.

9 OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, adopted 17 December 1997, 37 ILM 1 https://www.oecd.org/corruption/oecdantibriberyconvention.htm accessed 28 February 2025. 10 Financial Action Task Force (FATF) Recommendations, FATF https://www.fatfgafi.org/recommendations.html accessed 28 February 2025.

11 Council of Europe’s Criminal Law Convention on Corruption, ETS No 173 (adopted 27 October 1999)

https://www.coe.int/en/web/corruption/criminal-law-convention accessed 28 February 2025.

12 The Indian Penal Code, No. 45 of 1860, Acts of Parliament, 1860 (India).

13 The Indian Evidence Act 1872, Act No 1 of 1872 (India).

related to economic crimes. The Prevention of Corruption Act of 198814, this Act fortified the anti-corruption measures in the law by introducing Sections 13(1)(d) and 20, which allowed courts to presume guilty for possession of excess assets. Evidence such as asset audits and other financial records became the basis of conviction under this Act. M. Narsinga Rao v. State of Andhra Pradesh (2001)15 The Supreme Court held that circumstantial evidence could also prove the guilt of the offender in cases of Corruption in India, where direct evidence was absent. Neeraj Dutt v. State (Govt. of Delhi NCT) (2022)16 Emphasized the significance of circumstantial evidence in economic offenses, particularly in establishing the offense of bribery through the use of schemes and financial stratagems.

With improvements in technologies such as digital forensics, the value of circumstantial evidences has greatly improved. Modern courts now regard digital footprints, email communication, and financial transaction history in financial crime cases, especially in incidences of organizational fraud and cyber crimes as demonstrated in recent studies. The Criminological framework that supports Circumstantial evidence- Emphasizes the premeditated aspect of economic crimes. For example, theories of financial gain and concealment practices provide circumstantial evidence, which reveals the rationality of the criminals’ decision-making process. Covers financial crime as a reaction to the legitimate aspirations of the society.

Circumstantial evidence, such as rapid enhancements in social positions, gives a view on the offender’s purpose as well as the social position or structures within which the individual resides. Illustrates the strategies that offenders use to minimize their culpability. Such, or similar, lifestyle changes, or ‘hiding away’ certain assets, may help one understand these excuses, even when there is no confession. Courts have consistently ruled that circumstantial evidence must establish a complete chain of events leading to guilt without reasonable doubt. This evidence is crucial in demonstrating patterns of behavior or outcomes that strongly indicate corrupt practice. For example, In State of Maharashtra v. Dnyaneshwar Laxman Rao Wankhede (2009)17, The court emphasized the importance of circumstantial evidence, such as:

14 The Prevention of Corruption Act 1988, Act No 49 of 1988 (India).

15 M Narsinga Rao v State of Andhra Pradesh AIR 2001 SC 318.

16 Neeraj Dutt v State (Govt of Delhi NCT) (2022) SC

17 State of Maharashtra v Dnyaneshwar Laxman Rao Wankhede (2009) SC.

The accused’s sudden acquisition of disproportionate assets. • Inconsistent explanations for the source of income. • Lifestyle patterns inconsistent with known earnings. The case demonstrated how such evidence can create a logical chain that leads to the conclusion of guilt without requiring direct evidence of corrupt practices. Circumstantial evidence, also known as indirect evidence, engages in the art of deducing or drawing logical inferences from the intricate circumstances enveloping a particular event or situation. In opposition to direct evidence, which definitively establishes or refutes a fact, Circumstantial evidence relies on circumstances and requires analyzing facts and circumstances to come to a reasonable conclusion about what happened.

It gains strength from collecting various facts, events, and situations that, when considered, lead to a logical conclusion about the fact issue or the crime. 18 In India, the conception of circumstantial evidence within the arena of financial crimes has undergone profound changes because of the increasing sophistication of economic crimes as well as the demand for strong legal structures. In the past, the authenticity of circumstantial evidence was primarily founded on the sundry acts of concealment characteristic of financial crimes where direct evidence was frequently unavailable. In keeping with this advancement, it is evident that certain criminological theories are applicable where individual and environmental factors interact to create crime-consented opportunities.

1.1 NEERAJ DUTTA VS STATE (GOVT. OF DELHI NCT)

The Special Judge, Delhi found the Appellant guilty of offenses u/s 7 and u/s 13(1) (d)(i) and (ii) read with Section 13(2) of the Prevention of Corruption Act, 1988 (hereinafter referred to as ‘the PC Act’)19. The other accused, Mr. Yogesh Kumar, has been convicted for the offence under Section 12 of the PC Act. The High Court, however, acquitted the other accused. The Appellant was sentenced to three years of rigorous imprisonment and a fine of Rs. 15,000/- for the offence under Sub-section (2) of Section 13 of the PC Act. For the offence under Section 18 Divya Dubey and Manish Mehta, ‘The Significance of Circumstantial Evidence: Clues and Telltale Signs in Legal Proceedings’ (2022) 2 Journal of Legal Research & Juridical Sciences.

19 The Prevention of Corruption Act 1988, Act No 49 of 1988, ss 7, 13(1)(d), 20 (India).

7, she was sentenced to two years of rigorous imprisonment and a fine of Rs 5,000/-. Additional sentences for non-payment of the fines were also ordered. The High Court has confirmed the conviction of the Appellant. Mr. Ravijit Singh, the complaint lodger, passed on prior to the commencement of the trial. The complainant asserted that there was no meter installed in his store and there was a need of applying for an electric meter. An Inspector in the D. V. B. /electricity department, the Appellant invited the complainant to discuss the meter issue. She solicited a bribe of Rs. 15000/- for fixing the meter and Rs. 10000/-. The prosecution maintained that a trap was set up in pursuance of the complaint. The Special Court found that the circumstantial evidence available was enough to prove beyond reasonable doubt the culpability of the Appellant.

The evidence regarding the demand for gratification is missing in the case. The ingredients of the offence as defined under Section 7 of the PC Act are therefore not made out and consequently Section 13(1)(d) cannot be attracted. The Apex Court held that the appeal must be allowed. The conclusions reached by the impugned judgment and the Special Court are hereby set aside, as well as the petition's conviction and sentence, with all the petitioners’ bail bonds struck down. In its ruling, the Supreme Court emphasized on the need for circumstantial evidence in the establishment of the allegations as contained in the Prevention of Corruption Act, 1988. The ruling was on the issue of distinguishing between demand and illegal gratification, and the court emphasized the need to prove both demand and acceptance to establish guilt.

The court ruling also emphasized the option of the court to consider circumstantial evidence in instances where the complainant is absent so that trials would not be delayed and justice would not be compromised. The case of Neeraj Dutta demonstrates the problems associated with proving a financial crime in which no direct evidence is available. It also brings in the issue of pressing charges against individuals whose conduct seems criminal and the respect for individual freedoms. 20 The Supreme Court ruled that it is possible to convict an individual based on circumstantial evidence without calling any witnesses for the prosecution and where the witnesses available to testify are antagonistic to the prosecution case. This ruling is a step forward in protecting

20 ‘Validity of Circumstantial Evidence in Bribery Cases’ SC Observer (19 June 2023)

https://www.scobserver.in/cases/validity-of-circumstantial-evidence-in-bribery-cases/ accessed 28 February

public service, especially senior public offices such as the IAS and the IPS. It is commendable for the court that, while observing the downside of the unavailability of the complainant or of his demise, this should not halt the prosecution’s case. In all such occasions where the prosecution witnesses turn hostile due to bribery or other threats, the same broad reach of the law of evidence will now apply.

1.2. Argument in Support of Circumstantial Evidence in Financial Crime Cases

In the opinion of the court, the first thing that the prosecution must do to prove the guilt of the accused is to demonstrate the desire for and subsequent acquiescence to unlawful gratification. The court argues that direct evidence i.e. oral evidence or written evidence can prove this fact. The Constitutional Court also ruled that such a situation would allow for the use of circumstantial evidence, including the showing of a demand and acceptance of a bribe to prove that fact without any oral or documentary direct evidence. In India, circumstantial evidence plays a crucial role in reducing corruption by allowing the prosecution of public servants in cases where there is no direct evidence. It increases responsibility and acts as a deterrent to corrupt behavior. The following are some striking examples of cases that support my argument.

1. Direct Evidence is Rare in Financial Crimes

Criminal activities which involve finances are mostly unobserved activities, like bribery and embezzlement; they do not leave behind witnesses or tangible proofs. Offenders have advanced techniques, such as altering accounts or fabricating transactions, that makes the process of collecting evidence very challenging. However, in the absence of direct evidence, there are still other ways of understanding the offender’s purpose and the scheme’s dynamics, such as in the case of Harshad Mehta Scam. The Harshad Mehta scam in India 21In the early 1990s was a significant financial crime that highlighted the importance of circumstantial evidence in investigations. Mehta, a stockbroker, used fraudulent means to obtain credit from banks, purchasing large quantities of shares and artificially increasing their prices.

This led to a significant crash in the Indian stock market, causing substantial losses to investors. Weird banking activities, unexplained possession of wealth, and financial improvement over time are

21 Harshad S Mehta v CBI (1992) SC

example of circumstantial evidence that can help understand even without evidence facts. This case underscores the significance of circumstantial evidence in financial crime investigations, especially when direct evidence is difficult to obtain. Despite no direct evidence of Mehta's guilt, the overwhelming weight of circumstantial evidence led to his conviction and a significant prison sentence. In this scenario, explore how Mehta’s stock market interference in a strategic manner to create wealth fits into the Rational Choice Theory22. Furthermore elaborate on the circumstantial facts like sharp increases in Mehta's net worth, forged bank documents, and way of buying stocks, which showed his calculated risk taking, while at the beginning none of the evidence indicated that fraud had been committed.

The Rational Choice Theory suggests that Mehta balanced risks and rewards and calculated every detail to maximize the returns and remain hidden from the authorities. This reliance on circumstantial evidence by the court helps demonstrate the utility of Rational Choice Theory in the study of financial criminology.

2. Neutralization Theory and Rationalizations of Offenders

In C. K. Jaffer Sharief vs CBI23, highlighted the importance of circumstantial evidence in proving disproportionate assets under the PCA. Technological advancements, including phone tapping, financial monitoring systems, and surveillance methods, have increased the use of circumstantial evidence in corruption cases, such as digital footprints, emails, and financial trails. Courts now accept these as valid forms under the PCA, as seen in digital forensics cases. The presence of unexplained possessions supported the inference that bribes were likely taken even if the person did not say it. This perspective explains how the inner rationalizations and motives of the offender are presented as circumstantial evidence in support of the prosecution case. The Neutralization Theory24 states that deviant individuals frequently rationalize their conduct to smother feelings of guilt.

There are cases when offenders involved in bribery or fraud as a result of financial crime explain those offenses as a means to an end caused by low

22 Ronald V Clarke and Derek B Cornish, ‘Modeling Offenders’ Decisions: A Framework for Research and

Policy’ (1985) 6 Crime and Justice 147, 147–85.

23 C.K. Jaffer Sharief v. CBI, (2012) SC.

24 Gresham M Sykes and David Matza, ‘Techniques of Neutralization: A Theory of Delinquency’ (1957) 22 American Sociological Review 664, 664–70.

remuneration or unfair treatment. That's when the inner moral rationalizations come to be. Circumstantial evidence—such as evidence of lifestyle choices and asset accumulation—can reveal these justifications indirectly, showing courts how offenders reconcile illegal actions with personal rationalizations.

3. Circumstantial Evidence Addressing Lack of Oversight and Enabling Structures

Routine Activity Theory postulates that crime will take place when there is an opportunity, there is a person determined enough to commit the crime, and there is no one capable enough to prevent them from doing so. Even without direct proof of every illegal act, there is still circumstantial evidence that can show, for instance, how certain behavioral patterns regarding finances or associated disbursements of wealth can reveal lack of supervision to the extent that a crime was committed. As far as the Prevention of Corruption Act’s (PCA) workings are concerned, tendencies in the irregular ex-wealth accumulation or spending in the absence of enough oversight play the role of a ‘guardian’ within the judiciary, preventing attitudinal corruption in future offenders who perfectly engages in such empirical evidence.

Therefore, Routine Activity Theory 25underlines the importance of circumstantial evidence in explaining the means of the financial criminals, a further justification for their criminal activities.

4. Consistency and Reliability in Pattern Recognition

Evidence that is not direct, such as sudden gross prosperity or uneven and illogical financial processes, helps to reveal the motive strain to commit such crimes. For instance, as in the 2G Spectrum Case case, circumstantial evidence of malpractices in finances and acquisition of assets played a crucial role in showing that the accused was driven to disregard morals and the law due to external sociocultural and economic forces. This theory illustrates how circumstantial evidence illustrates the reasons above, showing that people do not simply offend; rather, they offend because social and economic expectations must be met.

5. Technological Advancements Strengthening Circumstantial Evidence

Technological progress has improved the effectiveness of circumstantial evidence. More reliance is placed on digital trails, such as emails and text messages, financial records, and 25 Lawrence E. Cohen & Marcus Felson, Social Change and Crime Rate Trends: A Routine Activity Approach,

44 Am. Sociological Rev. 588, 588–608 (1979).

phone logs, to demonstrate the commission of economic crimes. For instance, whether through data mining or monitoring, analytics can visualize and give evidence of clear anomalies in transactions or interactions within an individual’s digital footprints, thus improving circumstantial evidence.26

6. Circumstantial Evidence Mitigates Witness Vulnerability

In financial crimes, it is not unusual for potential witnesses to be scared into silence or, worse, may become hostile, making the collection of direct evidence extremely difficult. On the other hand, circumstantial evidence is not a product of relying merely on individual statements but is based on a logical evaluation of financial information and conduct. There is a well-known cardinal principle of evidence evaluation, which says, “Men may lie, but circumstances do not. 27”. Even though circumstantial evidence is by nature indirect, it can still be quite potent in court proceedings. However, its reception and assessment must be weighed judiciously to promote fairness and justice.

From the analyzed scenarios, it may be conclusively easier to establish that Circumstantial evidence is fundamental in investigating and prosecuting individuals suspected of financial crimes, especially when direct evidence is hard or impossible to come by. It enables detectives to link two or more ideas and deduce that a particular crime has occurred, for example, in cases like insider trading where attorneys have to prove the mens rea without any direct proof of such a mindset. The degree of relevancy of circumstantial evidence and the issue proved comes in different forms, from straight to intermediary ones. In the financial forensic setting, such evidence links certain actions and transactions, revealing the intention to commit a crime.

In addition, more and more courts are willing to recognize the claim that circumstantial evidence is necessary and sufficient in relation to the grounds for financial crimes, thus making the judicial process more appealing. Therefore, adapting to situations where evidence is scarce in complex financial crime cases emphasizes the high relevance of circumstantial evidence and serves the course of justice. Injustice anywhere is a threat to justice everywhere. 28 Many criminals are acquitted. The acquittals on grounds of no direct evidence for instance, in the 2G 26 Timothy Singleton, Aaron J Singleton, G Jack Bologna and Robert J Lindquist, Fraud Auditing and Forensic Accounting (John Wiley & Sons 2006).

27 Kamlesh & Ors v Attar Singh & Ors, Civil Appeal No 8879 of 2015 (SC).

28 Martin Luther King Junior

spectrum case drew public outrage sufficiently as to underscore the significance of circumstantial evidence in ensuring people’s faith in justice; in this connection, there is a requirement for the prosecution to depend on other credible evidence that supports the contentions of the prosecution and convict the criminal. In these circumstances, the circumstantial evidence plays a critical role as corroborative evidence in the beginning and later as crucial evidence. It is apparent that, in most cases, and especially under the Prevention of Corruption Act, Circumstantial evidence is critical in proving cases of corruption, as it assists the enforcement agencies in building a case where no direct evidence is available. The investigation must be forward-looking to respect the suspects' rights and safeguard the process's fairness and integrity without bias or guessing. 1. 3.

Legal and Policy Reforms in Anti-Corruption Framework A. Strengthening the Prevention of Corruption Act (PCA), 1988

Strengthening the legal framework and enforcement mechanisms is crucial for effectively tackling corruption in India, and key reforms are needed to achieve this goal. 1.The Prevention of Corruption Act (PCA), India's primary anti-corruption law, needs reforms to include clearer definitions of corruption, including emerging forms like quid pro quo arrangements, private sector corruption, and criminalizing bribe-giving and facilitation payments.29 2.Corruption trials often delay, causing low deterrence and ineffective punishment. To address this, special fast-track courts, strict investigation and trial timelines, and digitization of case records and e-courts are recommended.

3. The Whistleblowers Protection Act, 2014 requires stronger protection to discourage

underreporting of corruption cases due to fear of retaliation.30 B. Improving Conviction Rates in Corruption Cases

India's anti-corruption fight faces a low conviction rate in cases of bribery and misuse of public 29 The Prevention of Corruption Act 1988 (as amended in 2018) https://indiacode.nic.in accessed 28 February

30 The Whistle Blowers Protection Act 2014 https://indiacode.nic.in accessed 28 February 2025

office. To improve conviction rates, key reforms include enhancing investigative techniques, reducing political and bureaucratic interference, and strengthening anti-corruption agencies. Forensic accounting and financial tracking, along with increased investment in labs and training, should be used. Digital evidence, particularly electronic and cyber, is crucial for conviction. Legal oversight mechanisms should be introduced to ensure transparency and avoid bias. Agencies like Lokpal, CVC, and state vigilance commissions should be strengthened, and dedicated corruption courts should be established.

C. Adopting International Best Practices

India can learn from international best practices to strengthen its anti-corruption efforts. Hong Kong's Independent Commission Against Corruption (ICAC)31 has a three-pronged strategy, strict autonomy, and heavy use of technology in investigation and surveillance. Singapore's Corrupt Practices Investigation Bureau (CPIB)32 has extensive powers for investigation and prosecution, with strict laws and severe punishments. India can adopt a similar autonomous anti-corruption body with independent prosecutorial powers. The UK Bribery Act, 201033 imposes strict liability on companies for failing to prevent corruption, which India can adopt to ensure accountability for corruption by employees or agents.

CONCLUSION

In cases of corruption, the problem of acquiring direct evidence arises because many acts of corruption occur in secret. Instead, the chain of facts and events is created by circumstantial evidence, which is very important regarding the issues of culpability and law enforcement. Courts usually use circumstantial evidence when the direct link between the accused and the corrupt act cannot be quickly established. This is because corruption is often done secretively, making it hard to obtain any primary evidence in corruption cases. Circumstantial evidence is largely relied on by the courts, where it is not easy to connect the accused to the corrupt act through direct evidence almost immediately.

Where you do use circumstantial evidence, however, that circumstantial evidence must be of such quality as to eliminate all other possibilities so that no reasonable person in the judge's position could doubt it. Some judgments

31 Independent Commission Against Corruption (ICAC), Hong Kong: Official Reports and Case Studies.

Retrieved from: https://www.icac.org.hk

32 Singapore’s Corrupt Practices Investigation Bureau (CPIB): Annual Reports and Legal Framework.

Retrieved from: https://www.cpib.gov.sg

33 UK Bribery Act, 2010: Official Guidance. Retrieved from: https://www.legislation.gov.uk

have even been sustained by the Supreme Court in India, where a convict was found guilty of a corruption-related crime based mainly on circumstantial evidence, as long as the circumstances created a complete picture leading to a conviction. In this instance, this rather lenient provision of the law acknowledges that there are cases where proof of corrupt practices would not be in the boundaries of documents or witnesses. However, it leaves them in forms that are hard to prove, for example, unusual bank activities or even ownership of properties that cannot be accounted for. The role of circumstantial evidence in this issue is positive as it promotes the anti- impunity’s goal because it ensures that the law can be applied even without direct proof of the commission of the offense.

The framing of the circumstantial evidence assisted in plugging some of the gaps that criminals created to escape sanctions. In Neeraj Dutt case by allowing convictions based on strong circumstantial evidence, the judgment empowered anti-corruption mechanisms and sent a strong message against corrupt practices.