Can acceptance of gratification through an intermediary satisfy Section 7 of the Prevention of Corruption Act, 1988 only if the intermediary is shown to have acted under the accused's authority or direction?

Prevention of Corruption Act, 1988 — s.7 — s.13 — s.20 — Demand and acceptance — Approver evidence — Intermediary — PC Act, 1988 — s.20 — Foundational facts — Held: The presumption under Section 20 of the Act does not arise unless the prosecution establishes the foundational facts of demand and acceptance by the accused. Proof of demand may be circumstantial, but mere recovery of tainted currency without such proof does not establish the offence. (¶46, 47, 49) PC Act, 1988 — s.7 — Explanation 2 — Intermediary — Held further: Acceptance of gratification through an intermediary can satisfy Section 7 only if the intermediary is shown to have acted under the accused's authority or direction. Mere receipt of money by a third person cannot automatically fasten criminal liability on the public servant. (¶50, 51) Approver evidence — Corroboration — Held further: An approver's testimony must be corroborated in material particulars connecting the accused, not merely the transaction, with the offence. An accomplice who has secured pardon has an evident incentive to minimise his own culpability. (¶52, 53, 70) Chain of proof — Presumption — Held further: The chain of proof must be carried through cogent evidence to where the money is shown to have reached the accused. Recovery from an intermediary alone does not establish the money reached the accused, so the presumption under Section 20 does not arise; both appeals allowed and the appellant acquitted of all charges. (¶71, 74, 88)