BHUPESH DEB GUPTA (DEAD) BY L.RS. vs STATE OF TRIPURA

The Supreme Court held that for a conviction under Section 161 IPC, the prosecution must prove four essential ingredients: (1) the accused was a public servant at the time of the offence, (2) he accepted gratification from a person, (3) such gratification was not legal remuneration, and (4) it was accepted as a motive or reward for an official act. The Court found that the fourth ingredient was not fulfilled due to defects in the charge and the absence of a key witness. Consequently, the appeal was allowed, and the conviction was set aside.