Corruption offenses under the Prevention of Corruption Act cannot be quashed on the basis of compromise.

The applicant, an advocate, was representing the son of Non-applicant No. 3 (the original complainant) in a rape case (Crime No. 1/2018).

It was alleged that the applicant, acting as a middleman for police officers, demanded a bribe of ₹1.25 lakhs from the complainant to ensure "better facilities" for the son in jail.

The Anti-Corruption Bureau (ACB) conducted a verification trap and recorded conversations where the applicant discussed the demand and the distribution of money among police officers.

Consequently, an FIR was registered under Sections 7, 12, and 15 of the Prevention of Corruption (P.C.) Act, 1988.

Following the investigation and filing of the chargesheet, the applicant sought to quash the proceedings on two grounds: a mutual settlement with the complainant and the legal contention that he is not a "public servant" under the Act.

Whether criminal proceedings involving offences under the Prevention of Corruption Act can be quashed on the basis of a compromise or settlement between the informant and the accused.

Whether the applicant, not being a public servant, can be prosecuted under the P.C. Act for the offence of abetment.

The court relied on the Supreme Court precedents in State of Madhya Pradesh v. Laxmi Narayan, which prohibits quashing P.C. Act cases based on private settlements.

The court relied on State of Chhattisgarh v. Aman Kumar Singh, emphasizing "zero tolerance" toward corruption.

The court applied Section 7 (public servant taking gratification), Section 8 (taking gratification to influence public servants), and Section 12 (punishment for abetment) of the P.C. Act, 1988 (pre-2018 amendment).

It further integrated the definition of "abetment" under Section 107 of the Indian Penal Code (IPC), specifically Explanation-1 regarding instigation and intentional aiding.

The court rejected the compromise plea, noting that corruption is a "social malaise" and offences under special statutes like the P.C. Act cannot be quashed merely because the victim and offender settled.

Regarding the applicant’s status, the court conceded that as an advocate, he is not a "public servant" under Section 2(c), rendering Section 7 inapplicable to him directly.

However, the court found that the recorded evidence and voice samples—which matched the applicant's—prima facie established that he instigated the complainant to pay a bribe for the benefit of public servants (police officers).

This conduct falls squarely within the definition of "abetment" under Section 107 IPC.

Therefore, while Sections 7 and 15 were not attracted, the court held that a strong prima facie case existed under Section 12 (abetment) of the P.C. Act.

It held that while the applicant is not a public servant, he can be prosecuted for abetment under Section 12 of the P.C. Act.

The court further held that settlement between parties is irrelevant in corruption cases involving the public interest.

The interim relief was vacated, and the trial was allowed to proceed regarding the charge of abetment.