A court in Delhi has officially terminated a corruption case against a former bureaucrat and his wife after the Central Bureau of Investigation (CBI) submitted a report stating it found no substantial evidence of wrongdoing. The court accepted the closure report filed by the investigating agency.
The Case and Initial Allegations
The CBI had initially registered a First Information Report (FIR) on October 9, 2023, against Bhartendu Shandilya, an officer of the Delhi Administrative Sub-ordinate Services (DASS), and his wife, Lalita Shandilya (alias Lalita Sharma). The case was filed under the Prevention of Corruption Act, 1988, and Section 109 of the Indian Penal Code (IPC).
The allegations stemmed from source information claiming the couple possessed assets disproportionate to their known sources of income. The period under scrutiny was from January 1, 2012, to March 31, 2019. During this time, Shandilya was on deputation as the deputy resident commissioner to the Chandigarh Administration. He had joined government service in 2003 and took voluntary retirement on September 11, 2023.
The initial CBI calculation alleged that during the check period, the accused acquired assets worth approximately Rs 2.21 crore and spent about Rs 29.82 lakh against a total income of around Rs 1.63 crore. This resulted in alleged disproportionate assets of Rs 87.57 lakh, which was about 53.62% of his income. His wife was accused of abetting him in acquiring these assets.
Investigation Reveals Different Figures
During its detailed probe, the CBI meticulously collected and examined income tax returns and various financial documents. The investigation painted a different financial picture from the initial allegations.
The agency found that assets worth Rs 33.92 lakh were held at the start of the check period, which grew to Rs 3.51 crore by the end. Crucially, the total income during these years was recalculated to be significantly higher at Rs 3.76 crore. The total expenditure was assessed at Rs 68.79 lakh.
Based on these revised numbers, the value of disproportionate assets was calculated to be just Rs 9.78 lakh. This amount constituted a mere 2.59% of the total income, a figure far below the initial allegation.
Court's Decision Based on Legal Precedent
The case was presented before the court of Smita Garg, Special Judge (PC Act), at the Rouse Avenue District Court in New Delhi. In its order dated September 8, 2025, the court relied on a landmark Supreme Court judgment.
The judge cited the ruling in Krishnanand Agnihotri v. State of M.P. (AIR 1977 SC 796), which established that assets constituting less than 10% of the total income are not considered disproportionate under the law. Since the recalculated disproportionate assets were only 2.59%, well under the 10% threshold, the court found no grounds to proceed with the case.
The court accepted the CBI's closure report and ordered the case diaries to be returned to the Investigating Officer (IO). It also directed that all documents collected or seized during the investigation be returned to the individuals or agencies from whom they were taken. The IO was instructed to complete this process promptly.
This decision brings a legal conclusion to a case that had been pending for several years, absolving the former officer and his wife of the corruption charges based on the final findings of the central investigative agency.
