Ananda Kularatne v. Commissioner of Elections and Returning Officer of the Electoral District of Mulkirigala – sllr 1985 volume 2 page 164
In the case between Ananda Kularatne (petitioner) and Chandrananda de Silva, the Commissioner of Elections, among others (respondents), the Supreme Court addressed whether the constitutional and statutory framework allows for the disqualification of a candidate on grounds that an agent, acting with the candidate’s knowledge and consent, committed a corrupt practice. It was held that, under Article 89(e)(iii) of the 1978 Constitution, and considering the evolution from the 1946 Ceylon (Parliamentary Elections) Order in Council, disqualification requires a finding of personal guilt against the candidate. The provision “a report made by a Judge finding him guilty of any corrupt practice” was construed as applying only to an individual named personally as guilty, and not vicariously by reason

