At common law, bribery was a criminal offence, as described in Russell on Crimes:
"... the receiving or offering any undue reward by or to any person whatsoever, in a public office in order to influence his behavior in office and induce him to act contrary to the known rules of honesty and integrity."
In US v Adcock, Justice Stephenson wrote of bribery in distinguishing it from extortion, as follows:
"Bribery ... connotes a voluntary offer to obtain gain; where extortion connotes some form of coercion."
In Razete, Justice Allen used these words:
"Bribery, a common law crime, is the offering, giving, receiving or soliciting anything of value with the intent to influence the recipient's action as a public official."
REFERENCES:
- Razete v United States 199 Federal Reporter 2d 44 (1952)
- Russell on Crimes, 7th Edition, page 627.
- R v Hogg 19 D.L.R. 113 (Saskatchewan Supreme Court, 1914)
- United States v Adcock 558 Federal Reporter 2d 397 (1977)