AP High Court Halts Lok Adalat Acquittal in Tirumala Temple Theft Case, Orders CID Seizure of Records

In a significant exercise of its supervisory jurisdiction, the Andhra Pradesh High Court has intervened in a case involving an alleged theft scam at the globally renowned Tirumala Venkateswara Temple, suspending a Lok Adalat order that had acquitted the accused and directing the state's Crime Investigation Department (CID) to seize all related records.

The order, passed by Justice Gannamaneni Ramakrishna Prasad while hearing a writ petition filed in the public interest, casts a spotlight on the procedural integrity of Lok Adalat proceedings and the judiciary's role in safeguarding public trust in religious and administrative institutions. The court's directive not only reopens the investigation into the alleged misappropriation of temple offerings but also raises critical questions about the compounding of criminal offenses, particularly those involving a breach of trust.

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Background of the Alleged Scam and Questionable Acquittal

The controversy stems from the 'Parakamani' process, the traditional and highly sensitive system for counting the vast sums of cash, precious metals, and other offerings deposited by millions of devotees in the temple's Hundi. The Tirumala Tirupati Devasthanams (TTD), the independent trust managing the temple, is responsible for this intricate operation.

In 2023, a complaint was filed by Y. Satish Kumar, an Assistant Vigilance & Security Officer of the TTD, at the Town-I Police Station in Tirumala. This led to the registration of F.I.R. No. 24/2023 and, subsequently, a charge sheet against Sri C.V. Ravi Kumar. The charges were framed under Sections 379 (theft) and 381 (theft by clerk or servant of property in possession of master) of the Indian Penal Code, 1860. The latter section is particularly grave as it pertains to theft by an individual in a position of trust, carrying a higher potential penalty.

However, the case took an unexpected turn when it was brought before a Lok Adalat Bench in Tirupati. In proceedings dated September 9, 2023 (Lok Adalat Case No. 582 of 2023), the matter was summarily concluded. The record stated that the de-facto complainant had voluntarily compounded the offenses, leading to the outright acquittal of the accused, Sri C.V. Ravi Kumar. This resolution effectively closed the case, precluding any further criminal liability for the alleged theft from the temple's offerings.

High Court Intervention: A Matter of Public Interest

The acquittal via the Lok Adalat mechanism prompted a public interest challenge through a writ petition (W.P. No. 1294/2025) filed by M. Sreenivasulu. The petitioner brought the circumstances of the compounding and acquittal to the High Court's attention, demanding a comprehensive probe by the CID into what they termed a 'scam'.

Justice Prasad, recognizing the profound public interest implications of the matter, took immediate and decisive action. The court's primary concern appeared to be the legitimacy of the Lok Adalat's decision to permit the compounding of the offenses and the haste with which the matter was disposed of.

In a sharply worded interim order, the Court suspended the Lok Adalat's decision, stating:

"Having regard to the above facts, in public interest, this Court deems it appropriate to firstly suspend the Order of the Lok Adalat at Tirupati dated 09.09.2023 in Lok Adalat Case No.582 of 2023 in C.C.No.844 of 2023 in Crime No.24/2023 of I Town Police Station, Tirumala until further Orders.”

This suspension immediately nullifies the acquittal, reviving the criminal case against the accused pending the High Court's final determination.

Drastic Measures: CID Directed to Seize All Records

To ensure the integrity of the evidence and to facilitate a thorough review, the High Court went a step further, issuing an expansive directive to the state's premier investigating agency. Justice Prasad ordered the Inspector General of the CB-CID to take control of all relevant documents from every authority involved.

The court's direction was unequivocal:

“The IG, CB-CID, is directed to forthwith seize the entire record relating to F.I.R.No.24/2023 registered in Town-I Tirumala Police Station including the Proceedings before the Lok Adalat in Lok Adalat Case No.582 of 2023. The said Officer is also directed to seize the entire record from the TTD relating to the Board Resolutions, if any, and any other Proceeding made by any Official of the TTD and submit the same to the Court (properly sealed) for perusal before the next date of hearing…”

This sweeping order effectively quarantines the entire paper trail of the case—from the initial police FIR, to the questionable Lok Adalat proceedings, and crucially, any internal TTD records or resolutions pertaining to the matter. By ordering the seizure of TTD's internal documents, the court has signaled its intent to scrutinize not just the actions of the accused, but also the conduct of the institution and its officials in responding to the alleged theft.

Legal Analysis: The Non-Compoundable Nature of Section 381 IPC

The High Court's intervention brings a critical legal issue to the forefront: the compounding of offenses under the Code of Criminal Procedure, 1973 (CrPC). Section 320 of the CrPC specifies which offenses under the IPC are compoundable, i.e., can be settled between the victim and the accused, leading to an acquittal.

While simple theft under Section 379 IPC is listed as a compoundable offense (with the permission of the court, by the owner of the property stolen), Section 381 IPC—theft by a clerk or servant—is conspicuously absent from this list. It is a non-compoundable offense . The rationale is that such a crime constitutes not only a loss to the owner but also a grave breach of trust that has wider societal implications, and the state, therefore, retains an interest in its prosecution.

The apparent compounding of a non-compoundable offense by the Lok Adalat represents a fundamental procedural illegality. Lok Adalats, constituted under the Legal Services Authorities Act, 1987, derive their powers from the law and cannot act contrary to the express prohibitions contained within statutes like the CrPC. An award or order based on the compounding of a non-compoundable offense is void ab initio and an abuse of the legal process. The High Court's swift suspension of the order underscores this foundational principle.

Implications for the Justice System and Institutional Accountability

This case carries significant implications for legal practitioners and the judiciary:

1. Oversight of Lok Adalats: It serves as a potent reminder that while Lok Adalats are crucial for reducing judicial backlogs, their proceedings are not immune from judicial review. The High Courts, under their constitutional powers of superintendence (Article 227), can and will intervene to correct manifest errors of law and procedure, especially in matters of significant public interest.

2. Abuse of ADR Mechanisms: The case highlights the potential for Alternative Dispute Resolution (ADR) mechanisms to be misused to subvert the course of justice. Permitting the compounding of a serious, non-compoundable offense involving a public institution suggests a possible attempt to quickly bury a potentially embarrassing scandal.

3. Accountability of Public Trusts: The directive to seize TTD's internal records signals that institutions managing vast public and religious endowments are not beyond reproach. The court's inquiry may delve into whether there was any institutional complicity or negligence in the handling of the initial complaint and its subsequent settlement.

The matter is scheduled for its next hearing on October 13, 2025, by which time the CID is expected to have submitted the seized records to the court. The legal community will be watching closely as the High Court scrutinizes these documents, with its eventual ruling likely to set a firm precedent on the limits of Lok Adalat jurisdiction and the imperative of procedural correctness in the administration of criminal justice.