Saturday, 25 January 2025

Supreme Court: In Disproportionate Assets Cases, Income Tax Returns are Presumed To Be Accurate; The court Must Consider Inflation & Dynamic Factors

 We are of the view that the Appellant’s wife’s income

must be considered as well while calculating the total

income and assets. Both the Appellant and his wife

have filed the relevant income tax returns in order to

show their respective incomes and assets. The

Respondents in their Counter-Affidavit have not

denied these income tax returns or alleged them to be

forged or fabricated. Therefore, when a public servant

is submitting his income tax returns, they should be

presumed to be true and correct. If you duly consider

the income tax returns of the Appellant and his wife

for the check period of the year 1996-2020, the total

income is coming up to be Rs.1,21,06,268/-(Rupees

One Crore Twenty One Lakh Six Thousand Two

Hundred Sixty Eight only) which is in fact more than

the assets amounting to Rs.1,16,02,669/- (Rupees

One Crore Sixteen Lakh Two Thousand Six Hundred

Sixty Nine only) which is said to be the

disproportionate assets in question under the present

FIR. {Para 9}

10. Further, we have considered that the check period is

from the year 1996 to 2020, which is almost twenty

five years. It must be taken into account that over

such a long period of time, there is inflation and a

natural progression in the changing economy that

affects the value of assets such as property. This can

understandably lead to discrepancies in declaring the

value of assets over the years. Therefore, there should

be a more dynamic approach while considering an

individual’s income and assets over the span of two

decades, such as in the present case. The notion that

the declared value of an asset such as property or gold

will remain static is flawed. This has to be considered

while examining an individual’s assets and income

while making a determination regarding

disproportionate assets. Such an examination needs

to reflect such adjustments and changes as is natural

with the progression of time.

11. We find it pertinent to note that in cases such as these

where disproportionate assets are being dealt with,

the amounts under scrutiny cannot be looked at in

the same manner as one would do a Bank statement

or daily ledger of income and expenditure. The

scrutiny process cannot be as mechanical as that

when you are examining declared assets and the

income of an individual over such a long period of

time. There has to be a certain margin that is given

while making such an assessment as there are

invariably economical fluctuations that would have

taken place, especially over the course of nearly

twenty-five years. It is crucial to have a nuanced

appreciation of how time and economic conditions

affect asset value in such cases.

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL NO.5009 OF 2024

[ARISING FROM SLP (Crl.) No. 10101/2024]

NIRANKAR NATH PANDEY   Vs  STATE OF U.P. & ORS. 

Dated: DECEMBER 04, 2024. 

1. Leave granted.

2. The Appeal before us is against the order of the High

Court of Allahabad dated 11.01.2024 whereby the

High Court has refused to quash the FIR lodged

against the Appellant.

3. The factual background of the present case is that FIR

No.0002 of 2023 dated 17.10.2023 was registered as

Case Crime No.0002 of 2023 against the Appellant

under Section 13(1)(b) read with Section 13(2) of

Prevention of Corruption Act, 1988(Hereinafter, PC

Act). The Appellant filed Criminal Miscellaneous Writ

Petition No.18777 of 2023 before the High Court for

quashing of the said FIR. The High Court vide order

dated 11.01.2024 dismissed the Appellant’s Writ

Petition. Aggrieved by this, the Appellant is before us.

4. Prior to the present FIR, another FIR was lodged in the

year 2018, bearing Case Crime No.476 of 2018 for

offences under Section 420, 467, 468, 471, 120B of

the Indian Penal Code, 1860 read with Section 13(1)(d)

and 13(2) of the PC Act in Police Station Kotwali,

District Fatehpur, U.P against some officials of the

Excise Department, U.P., wherein the present

Appellant was implicated and he was subsequently

enlarged on bail. This Case Crime No.476 of 2018 is

pending before the Trial Court.

5. Due to the earlier FIR, a notice dated 25.08.2020 was

issued to the Appellant by the Department of Vigilance

Establishment, U.P. whereby the Appellant was

directed to submit the Statement of Declaration of

Assets and other income details. Pursuant to this

notice, the Appellant submitted all such details before

the Uttar Pradesh Vigilance Department.

6. The Appellant was working as Assistant Excise

Commissioner when the Uttar Pradesh Vigilance

Establishment initiated an inquiry against him. This

open inquiry disclosed the Appellant’s income from

known and legitimate sources during the period of

checking as Rs.94,28,605/- (Rupees Ninety Four Lakh

Twenty Eight Thousand Six Hundred Five only). For

the same period, the Appellant was found to have

amassed assets including living expenses worth

Rs.1,16,02,669/- (Rupees One Crore Sixteen Lakh

Two Thousand Six Hundred Sixty Nine only). The

Appellant is said to have amassed assets including

expenses of around Rs.21,74,064/- (Twenty One Lakh

Seventy Four Thousand Sixty Four only) more than

his known income. This is said to be the

disproportionate assets in question. The Inquiry

Report was forwarded to the Government on

20.03.2023 by the Joint Director, Uttar Pradesh

Vigilance Establishment and directions were issued

vide Demi-Government Letter dated 20.04.2023

issued by the Vigilance Department, Government of

U.P. for institution of criminal proceedings against the

Appellant. Consequent to this, the present FIR was

registered against the Appellant based on the

complaint of Inspector, Uttar Pradesh Vigilance

Establishment Sector, Ayodhya.

7. We have heard the learned counsel for the parties and

perused the relevant material.

8. The Appellant has declared his and his wife’s assets

consequent to notice dated 25.08.2020. It is stated

that the wife of the Appellant is also earning from

teaching yoga, agriculture, and from receiving house

rent. It is submitted that the Appellant’s total income

since 1996 to 2020 is Rs.75,73,676/- (Seventy-Five

Lakh Seventy-Three Thousand Six Hundred Seventy

Six only) and the income of his wife during the

aforesaid period is about Rs.41,67,592/- (Rupees

Forty One Lakh Sixty Seven Thousand Five Hundred

Ninety Two only). These declarations are supported by

the relevant income tax returns. The ornaments of the

Appellant’s wife have been sold for an amount of

Rs.2,16,000/- (Rupees Two Lakh Sixteen Thousand

only) and the Appellant received Rs.1,00,000/-

(Rupees One Lakh only)from a Life Insurance Policy

4

plus there is an amount of Rs.49,000/- (Rupees Forty

Nine Thousand only)that was given to the Appellant by

his father. Therefore, the total income and assets of

the Appellant and his wife has been submitted to be

Rs.1,21,06,268/- (Rupees One Crore Twenty One

Lakh Six Thousand Two Hundred Sixty Eight only)

during the period of 1996 to June 2020. Further, the

Appellant has explained and submitted documents

regarding the properties owned by him and his wife

and a loan given by the Bank. This has not been

considered by the Uttar Pradesh Vigilance

Department. The present FIR is lodged on the basis of

the Uttar Pradesh Vigilance Establishment prima facie

finding the Appellant guilty. However, if we consider

the declared assets of the Appellant and his wife for

the aforesaid period it comes up to Rs.1,21,06,268/-

(Rupees One Crore Twenty One Lakh Six Thousand

Two Hundred Sixty Eight only). The present FIR states

the disproportionate assets to be Rs.1,16,02,669/-

(Rupees One Crore Sixteen Lakh Two Thousand Six

Hundred Sixty Nine only) for the same period.

9. We are of the view that the Appellant’s wife’s income

must be considered as well while calculating the total

income and assets. Both the Appellant and his wife

have filed the relevant income tax returns in order to

show their respective incomes and assets. The

Respondents in their Counter-Affidavit have not

denied these income tax returns or alleged them to be

forged or fabricated. Therefore, when a public servant

is submitting his income tax returns, they should be

presumed to be true and correct. If you duly consider

the income tax returns of the Appellant and his wife

for the check period of the year 1996-2020, the total

income is coming up to be Rs.1,21,06,268/-(Rupees

One Crore Twenty One Lakh Six Thousand Two

Hundred Sixty Eight only) which is in fact more than

the assets amounting to Rs.1,16,02,669/- (Rupees

One Crore Sixteen Lakh Two Thousand Six Hundred

Sixty Nine only) which is said to be the

disproportionate assets in question under the present

FIR.

10. Further, we have considered that the check period is

from the year 1996 to 2020, which is almost twenty

five years. It must be taken into account that over

such a long period of time, there is inflation and a

natural progression in the changing economy that

affects the value of assets such as property. This can

understandably lead to discrepancies in declaring the

value of assets over the years. Therefore, there should

be a more dynamic approach while considering an

individual’s income and assets over the span of two

decades, such as in the present case. The notion that

the declared value of an asset such as property or gold

will remain static is flawed. This has to be considered

while examining an individual’s assets and income

while making a determination regarding

disproportionate assets. Such an examination needs

to reflect such adjustments and changes as is natural

with the progression of time.

11. We find it pertinent to note that in cases such as these

where disproportionate assets are being dealt with,

the amounts under scrutiny cannot be looked at in

the same manner as one would do a Bank statement

or daily ledger of income and expenditure. The

scrutiny process cannot be as mechanical as that

when you are examining declared assets and the

income of an individual over such a long period of

time. There has to be a certain margin that is given

while making such an assessment as there are

invariably economical fluctuations that would have

taken place, especially over the course of nearly

twenty-five years. It is crucial to have a nuanced

appreciation of how time and economic conditions

affect asset value in such cases.

12. This Court has held in State of Haryana vs. Bhajan

Lal, 1992 SCC (Cri) 426 that when allegations made in

the first information report or the complaint, even if

they are taken at their face value do not prima facie

constitute any offence or make out a case against the

accused, powers under Article 226 of the Constitution

of India could be exercised to prevent abuse of the

process of any court. We find that the present FIR in

question and the case against the Appellant is covered

under these findings in Bhajan Lal (supra).

13. In view of the above discussion, we find it appropriate

to quash FIR No, 0002 of 2023 dated 17.10.2023


pending against the Appellant. Consequently, the

appeal is allowed.

14. Pending application(s) shall stand disposed of.

....................,J.

 (VIKRAM NATH)

....................,J.

 (PRASANNA B. VARALE)

 NEW DELHI;

DECEMBER 04, 2024. 

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