Dr. Mohankumar, a practicing doctor, was accused of helping launder illicit money for a public servant (Accused No. 1). The prosecution alleged that Dr. Mohankumar transferred 25 lakh to M.S. Ramaiah Medical College to secure a Pediatrics MD seat for the daughter of Accused No. 1.
Karnataka: The Karnataka High Court clarified that courts should base their decisions on the evidence collected by investigating officers and avoid considering defenses during the discharge stage of a case.
The ruling, delivered by Justice H.P. Sandesh, came in the case of Criminal Revision Petition No. 118/2024, filed by Dr. Mohankumar M., who challenged the trial court’s decision to reject his application for discharge in a corruption case.
Background of the Case
Dr. Mohankumar, a practicing doctor, was accused of helping launder illicit money for a public servant (Accused No. 1). The prosecution alleged that Dr. Mohankumar transferred 25 lakh to M.S. Ramaiah Medical College to secure a Pediatrics MD seat for the daughter of Accused No. 1.
The amount was allegedly linked to unexplained cash deposits in Dr. Mohankumar’s bank account, including 17.5 lakh and 29.95 lakh, which were deposited shortly before the transaction.
The charges against Dr. Mohankumar included offenses under Sections 13(1)(d) and 13(1)(e) read with 13(2) of the Prevention of Corruption Act, 1988, and Section 109 of the Indian Penal Code (IPC). In his defense, Dr. Mohankumar claimed that the funds were his own, earned through legal means, and that the financial assistance was extended out of goodwill.
Key Issues in the Case
The court addressed several key legal questions during the ruling:
- Prima Facie Evidence for Prosecution: Did the evidence collected by the investigating officers establish sufficient grounds for proceeding with the trial against Dr. Mohankumar?
- Scope of Discharge Applications: Should the court consider the petitioner’s claims of legitimate sources of funds during the discharge stage?
- Effect of Quashing Proceedings Against Accused No. 1: Did the quashing of charges against the primary accused affect the proceedings against Dr. Mohankumar?
Court’s Observations
Justice Sandesh provided a detailed analysis of the legal and factual aspects of the case. He made several key observations:
- Limited Scope of Discharge Applications: The court emphasized that the discharge stage is not meant to examine the defenses or alternative theories of the case in detail. The purpose of this stage is to determine whether there is sufficient evidence for the charges to proceed. Justice Sandesh stated, “The court cannot engage in a mini-trial at the stage of discharge. Judges must rely exclusively on the material collected by the investigating officers.“
- Unexplained Financial Transactions: The court highlighted suspicious financial transactions, particularly the sudden cash deposits made by Dr. Mohankumar in his account just before the transfer of 25 lakh. These transactions raised doubts, especially since the petitioner’s declared income did not match the amounts deposited. The court noted these deposits as significant evidence in the case.
- Comparison with Co-Accused: Dr. Mohankumar argued that other co-accused individuals had been discharged by the trial court. However, the High Court identified crucial differences. For example, Accused No. 3 was discharged after it was found that the payment was an interest-free loan sanctioned by a committee, and Accused No. 5 provided sufficient evidence of financial resources to justify the transaction. In contrast, Dr. Mohankumar could not explain the source of the substantial cash deposits in his account, which was a key issue in the case.
- Effect of Quashing Proceedings Against Accused No. 1: Dr. Mohankumar contended that, since the charges against the main accused, Accused No. 1, were quashed by the High Court, the case against him should also be dropped. However, Justice Sandesh clarified that the quashing order was being challenged before the Supreme Court and could not be used to justify the discharge of Dr. Mohankumar. The judge stated, “The quashing order was under challenge before the Supreme Court and could not be relied upon to discharge the petitioner.“ He further observed that the petitioner’s actions were independently subject to scrutiny under the Prevention of Corruption Act, irrespective of the status of the primary accused.
- Judicial Precedents: Justice Sandesh referred to previous judgments, stressing that at the discharge stage, courts must not evaluate the evidence in detail or consider defenses. The focus should only be on whether the prosecution has provided enough evidence to establish a prima facie case.
Court’s Final Decision
After considering the facts and legal principles, the Karnataka High Court upheld the trial court’s decision to reject Dr. Mohankumar’s discharge application. The court found that the prosecution’s evidence presented a prima facie case against Dr. Mohankumar. The unexplained cash deposits and the timing of the transactions were deemed suspicious and relevant in this context.
Justice Sandesh concluded,
“The prosecution’s evidence demonstrates sufficient grounds to proceed with the charges against the petitioner. The unexplained cash deposits and the timing of the transactions establish a prima facie case of abetment.”
He added that Dr. Mohankumar’s explanations could only be tested during the trial, and could not serve as grounds for discharge.
Thus, the petition was dismissed, and the case will proceed to trial.
