Allahabad High Court Grants Bail to Labour Officer, Flags Major Irregularities in Corruption Trap

The Allahabad High Court has granted bail to Labour Enforcement Officer Suresh Prakash Gautam, accused of demanding a bribe of Rs. 15,000 and allegedly being caught red-handed by an anti-corruption trap team, after finding multiple irregularities in the trap proceedings and gaps in the investigation.

The bench of Justice Sameer Jain passed the order in Gautam’s bail plea under Section 7 of the Prevention of Corruption Act.

According to the prosecution, the officer had demanded illegal gratification to process a worker’s claim and was arrested during a trap in which the marked currency was recovered from him. The State argued that the officer held an important position and had violated the trust placed in him by seeking bribe money. It further pointed to the recovery of about Rs. 21.5 lakh from his residence during the investigation.

However, court noted that several circumstances raised doubts about the integrity of the trap itself. The FIR showed that neither the officer’s nor the complainant’s hands were washed at the spot to test for chemical traces of the tainted currency, nor was the recovered money sealed at the place where the trap was executed. Even the recovery memo was not prepared at the scene but later at the police station. The judge observed that these deviations from established anti-corruption procedures could not be overlooked at the stage of deciding bail.

Court also took note of the officer’s prior complaint dated August 14, 2025, which was made a week before the trap, where he alleged that some colleagues were conspiring to implicate him in false cases. The complainant’s application, which formed the basis of the alleged bribe demand, was found to have defects that could reasonably have prevented its processing, supporting the officer’s argument that there was no occasion for him to seek a bribe. These issues, according to the court, lent some credibility to his claim of false implication.

On the seizure of Rs. 21.5 lakh from Gautam’s home, court highlighted another major investigative lapse. Despite the substantial amount recovered, the investigating officer did not probe its source or link it to the alleged offence. The chargesheet was filed only for the offence under Section 7 of the PC Act, without invoking provisions relating to disproportionate assets. The applicant, meanwhile, claimed the money came from the sale of agricultural produce and eucalyptus trees, an explanation the court said could not be rejected outright without investigation.

Court further recorded that Gautam had no criminal history and had remained in custody since August 25, over three months, with the investigation already complete. Reiterating that bail should not be refused for punitive reasons and that an accused is presumed innocent until proven guilty, court concluded that the applicant had made out a case for bail.

Court directed that Gautam be released on furnishing a personal bond and two sureties, subject to conditions restraining him from influencing witnesses or engaging in criminal activity.

In a significant postscript, court also criticised the broader pattern of investigative shortcomings in corruption cases.

Observing that trap procedures are routinely carried out in a “most casual manner,” the judge directed the Uttar Pradesh Principal Secretary (Home) and the Director General of Police to issue instructions ensuring that hand-wash tests, sealing of currency, and preparation of recovery memos are conducted strictly at the trap site to preserve the sanctity of evidence.

Court ordered the Registrar General to forward the court’s directions to the authorities for compliance.

Case Title: Suresh Prakash Gautam vs. State of UP

Order Date: December 1, 2025

Bench: Justice Sameer Jain