R. G. JACOB vs UNION OF INDIA

The Supreme Court interpreted 'subordinate' in Section 165 of the Indian Penal Code, affirming that it encompasses all subordinates without functional qualifications. The Court upheld the conviction of an Assistant Controller of Imports for accepting valuable things to assist in securing an export permit, rejecting the argument that he was not functionally subordinate to the Joint Chief Controller of Imports and Exports. The conviction was affirmed, emphasizing the legislative intent behind the term 'subordinate'.