TRILOK CHAND JAIN vs STATE OF DELHI

The Supreme Court held that for a conviction under Section 161 IPC, it is essential to establish that the accused received gratification as a motive for an official act. The Court found that the appellant, a mere labourer, did not have the capacity to influence any official action and thus lacked the requisite mens rea. The conviction under Section 5(1)(d) of the Prevention of Corruption Act was also unsustainable as the prosecution failed to prove that the appellant obtained money through corrupt means. Consequently, the Court allowed the appeal and set aside the conviction.