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Supreme Court Upholds Quashing of FIR in Telangana MLC Vote Bribery Case: No Evidence Against Accused

Court says allegations were vague and unconnected to actual bribery incident

Ruling reinforces principle that criminal cases cannot continue without solid evidence

By Our Legal Reporter

New Delhi: September 30, 2025: In a significant ruling, the Supreme Court of India has upheld the Telangana High Court’s decision to quash the criminal case against one of the accused in the 2015 MLC (Member of Legislative Council) vote bribery case, popularly known as the cash-for-vote scam. The apex court dismissed the appeals filed by the State of Telangana and the complainant MLA, observing that there was “nothing to connect the accused (A4) to the crime” except for a casual allegation.

The judgment, delivered by a bench of Chief Justice B.R. Gavai and Justice K. Vinod Chandran, has once again highlighted the importance of evidence-based prosecution and the dangers of pursuing criminal cases based on vague or unsubstantiated claims.

Background of the Case

The controversy dates to May 2015, when a complaint was filed by Telangana MLA Elvis Stephenson with the Anti-Corruption Bureau (ACB). The MLA alleged that he had been offered ₹2 crore by one of the accused (referred to as A4 in court documents) to either vote in favor of a particular political party in the upcoming MLC elections or to abstain from voting by leaving the country.

The complaint further mentioned that another individual later increased the offer to ₹5 crore, allegedly on behalf of other political figures. However, the complaint did not specify when the calls were made, nor did it provide details of the MLA’s response.

On May 31, 2015, ACB officials conducted a sting operation at the residence of a friend of the complainant. They recorded audio and video evidence of a transaction involving other accused persons. Importantly, A4 was not present during this incident.

Despite this, an FIR was registered under Section 12 of the Prevention of Corruption Act, 1988, naming A4 among the accused.

Arguments Before the Court

State of Telangana and Complainant’s Stand

Senior Advocate Dr. Menaka Guruswamy, appearing for the Telangana government, along with counsel for the complainant, argued that the High Court had erred in quashing the FIR. They claimed that the High Court had effectively conducted a “mini-trial”, which the Supreme Court has previously disapproved of.

They further argued that the FIR, sting recordings, and recovery of bribe money established a prima facie case of corruption, and therefore, the matter should have gone to trial instead of being dismissed at the preliminary stage.

Defence of the Accused (A4)

On the other hand, the counsel for A4 argued that there was “absolutely no material” linking him to the alleged bribery. The only reference to him was a casual mention in the complaint, without any supporting evidence. They contended that the allegations were improbable, vague, and unsubstantiated, and therefore, the High Court was right in quashing the proceedings.

Supreme Court’s Analysis

The Supreme Court carefully examined the complaint, the FIR, and the High Court’s reasoning. Justice K. Vinod Chandran, writing the judgment, made several key observations:

No direct evidence against A4: The Court noted that A4 was not present during the sting operation on May 31, 2015, when the alleged bribery transaction was recorded.
Disconnected allegations: The complaint mentioned two separate offers of money, but there was no link between them. The allegation against A4 was not connected to the later incident involving other accused persons.
Casual allegation insufficient: The Court emphasized that the only reference to A4 was a casual allegation of a phone call, with no details of time, place, or corroboration.
High Court’s reasoning valid: While the High Court’s order was lengthy, the Supreme Court said it contained justifiable reasons for quashing the FIR.

The bench concluded:

“There is nothing to connect A4 to the crime, but for a casual allegation raised on a call having been received by the complainant without any indication even of the time when such call was received.”

Accordingly, the Supreme Court dismissed the Special Leave Petitions (SLPs) filed by the State of Telangana and the complainant.

Legal Significance of the Judgment

This ruling is important for several reasons:

Reinforces the principle of evidence-based prosecution: The Court made it clear that mere suspicion or casual allegations cannot justify the continuation of criminal proceedings.
Prevents misuse of criminal law: The judgment protects individuals from being dragged into long legal battles without credible evidence.
Clarifies limits of judicial review: The Court rejected the argument that the High Court had conducted a “mini-trial,” stating that quashing is justified when allegations are vague and disconnected.
Impact on political bribery cases: The ruling may influence how future cases of alleged vote-buying are investigated and prosecuted, especially in politically sensitive contexts.

Wider Context: Bribery and Electoral Integrity

The cash-for-vote scam of 2015 was a major political controversy in Telangana and Andhra Pradesh. It raised serious questions about the integrity of electoral processes and the influence of money in politics.

While the Supreme Court’s ruling does not absolve all accused in the case, it underscores the need for strong, admissible evidence before prosecuting individuals. The judgment also comes at a time when the Court has been actively addressing issues of corruption and bribery among legislators.

In March 2024, a seven-judge Constitution Bench ruled that MLAs and MPs do not enjoy immunity under Articles 105(2) and 194(2) of the Constitution in cases of bribery. This landmark decision ensures that lawmakers can be prosecuted if they accept or solicit bribes in connection with their legislative functions.

Conclusion

The Supreme Court’s decision to uphold the quashing of the FIR against A4 in the 2015 MLC vote bribery case is a reminder that criminal law cannot be used as a tool of harassment. Allegations must be backed by clear, credible, and connecting evidence.

While the larger issue of money power in elections remains a challenge for Indian democracy, this ruling ensures that individuals are not unfairly prosecuted on the basis of vague or casual claims.

The judgment strengthens the principle that justice must be rooted in evidence, not speculation.

SC Quashes FIR in Telangana MLC Vote Bribery Case