Aman Bhatia vs State (GNCT of Delhi), 2025

The appellant, Aman Bhatia, was a stamp vendor who faced charges under the Prevention of Corruption Act, 1988 for allegedly demanding an excess amount of Rs. 2 for a stamp paper worth Rs. 10.

The purchaser filed a complaint, which led to the Anti-Corruption Bureau initiating proceedings against the appellant, including a trap operation to catch the appellant in the act.

The Trial Court convicted the appellant under Sections 7 and 13(1)(d) read with Section 13(2) of the PC Act.

The Delhi High Court upheld the conviction, prompting the appellant to appeal to the Supreme Court.

The Supreme Court ruled that stamp vendors are public servants under Section 2(c)(i) of the Prevention of Corruption Act, 1988.

The Court emphasized that the status of a public servant is determined by the nature of the duty being performed, not the formal designation of the individual.

Stamp vendors, by selling government-issued stamp papers, are performing a public duty and are remunerated by the government through discounts on stamp paper purchases.

The Court held that since stamp vendors are performing duties that serve the public interest and are remunerated by the government, they qualify as public servants under the PC Act.

Despite the appellant being found to be a public servant, the Court noted that the prosecution failed to prove beyond a reasonable doubt that the appellant demanded an illegal gratification and accepted a bribe.

As a result, the Court overturned the conviction, citing insufficient evidence to conclusively prove the allegations.

The judgment expands the definition of public servants under the Prevention of Corruption Act, now covering private individuals performing public duties and receiving government remuneration.

The Court clarified the link between public duties and remuneration: stamp vendors receive government compensation via discounts on stamp papers, thus falling within the ambit of public servants.

The vending of stamp papers is essential to the government’s collection of stamp duty, reinforcing the role of stamp vendors in fulfilling public duties.

Evidence Standard: While the Court ruled that stamp vendors are public servants, it also emphasized the importance of evidence in proving criminal liability, leading to the overturning of the conviction.

The Court referred to previous rulings, such as State of Gujarat vs Mansukhbhai Kanjibhai Shah, to highlight that remuneration tied to public duties qualifies individuals as public servants, irrespective of whether they are formally employed by the government