Thursday, 27 June 2024

Important Supreme Court Judgments on bail(Part 3)

 

1) Supreme Court: Participation in protest and expression of strong views is not violation of bail conditions-bail is not liable to be cancelled on that ground


IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL NO.1994 OF 2024

A.DURAIMURUGAN PANDIYAN SATTAI @ DURAIMURUGAN  VS. STATE REP. BY THE INSPECTOR OF POLICE & ANR.

Dated: April 08, 2024.



2) Supreme Court: PMLA Accused Who Has Spent Half Of Maximum Sentence As Undertrial Can Be Given Bail Under S.436A CrPC


IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL NOS.2601-2602 OF 2024

AJAY AJIT PETER KERKAR  VS. DIRECTORATE OF ENFORCEMENT & ANR.

Dated: May 16, 2024.

https://www.lawweb.in/2024/05/supreme-court-pmla-accused-who-has.html


3) Supreme Court: Factors which Appellate court should consider for setting aside bail order


 Bail can also be revoked by a superior Court if it transpires that the courts below have ignored the relevant material available on record or not looked into the gravity of the offence or the impact on the society resulting in such an order.

28. The considerations that weigh with the appellate Court for setting aside the bail order on an application being moved by the aggrieved party include any supervening circumstances that may have occurred after granting relief to the Accused, the conduct of the Accused while on bail, any attempt on the part of the Accused to procrastinate, resulting in delaying the trial, any instance of threats being extended to the witnesses while on bail, any attempt on the part of the Accused to tamper with the evidence in any manner.  

 IN THE SUPREME COURT OF INDIA

Criminal Appeal No. 2639 of 2024 

Decided On: 17.05.2024

Ajwar Vs. Waseem and Ors.

Author: Hima Kohli, J.

Citation:  MANU/SC/0462/2024.

https://www.lawweb.in/2024/05/supreme-court-factors-which-appellate.html

4) Supreme Court: Same Court can cancel the Bail Which had Granted It If There Are Serious Allegations Even If Accused Hasn't Misused Bail


 IN THE SUPREME COURT OF INDIA

Criminal Appeal No. 2639 of 2024 

Decided On: 17.05.2024

Ajwar Vs. Waseem and Ors.

Author: Hima Kohli, J.

Citation:  MANU/SC/0462/2024.

5) Supreme Court: Grant or refusal of a bail application is an interlocutory order

It cannot be doubted that the grant or refusal of a bail application is essentially an interlocutory order. There is no finality to such an order for an application for bail can always be renewed from time to time.

 IN THE SUPREME COURT OF INDIA

Criminal Appeal No. 313 of 1987 

Decided On: 14.03.1988

Usmanbhai Dawoodbhai Memon and Ors. Vs. State of Gujarat

Hon'ble Judges/Coram:

A.P. Sen and L.M. Sharma, JJ.

Author: A.P. Sen, J.

Citation: MANU/SC/0560/1988 : 1988 (2) SCC 271.

https://www.lawweb.in/2024/05/supreme-court-grant-or-refusal-of-bail.html

6) Whether the court can give personal exemption to accused if he has not given the bail?

Further, the observation that there is no provision for granting exemption from personal appearance prior to obtaining bail, is not correct, as the power to grant exemption from personal appearance under the Code.{ Section 205 of the Code. Also see, Section 317 of the Code}  should not be read in a restrictive manner as applicable only after the accused has been granted bail. 

REPORTABLE

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL NO. OF 2024

SHARIF AHMED AND ANOTHER Vs STATE OF UTTAR PRADESH AND ANOTHER

Author: SANJIV KHANNA, J.

Dated: MAY 01, 2024.

Citation: 2024 INSC 363.

7) Whether the court should stay bail granted to accused to ensure fair trial to victim of an offence Under the Pocso Act?

Having considered the submissions and perused the

material on record, we are prima facie of the view

that in order to ensure a fair trial not only to the

accused but also to the victims, it would be in the

interest of justice that the respondent no. 3 may

remain in custody during the time the witnesses of

fact are examined.

S U P R E M E C O U R T O F I N D I A

RECORD OF PROCEEDINGS

Petition(s) for Special Leave to Appeal (Crl.) No(s). 13943/2023

H. EKANTHAIAH Vs THE STATE OF KARNATAKA & ANR. 

CORAM :

HON'BLE MR. JUSTICE VIKRAM NATH

HON'BLE MR. JUSTICE PRASHANT KUMAR MISHRA

Date : 23-04-2024.

https://www.lawweb.in/2024/05/whether-court-should-stay-bail-granted.html

8) Supreme Court: The Courts should give expanded interpretation to S 436A of CRPC for expediating release of the accused on bail


IN THE SUPREME COURT OF INDIA

Miscellaneous Application No. 1849 of 2021 in Special Leave Petition (Crl.) No. 5191 of 2021 

 Satender Kumar Antil Vs. Central Bureau of Investigation and Ors.

Hon'ble Judges/Coram:

Sanjay Kishan Kaul and M.M. Sundresh, JJ.

Author: M.M. Sundresh, J.

Decided On: 11.07.2022

Citation: MANU/SC/0851/2022.

9) Can the appellate court give the benefit of S 436A of CRPC to the accused when criminal appeal or revision is pending?


 Section 436A of the Code has been inserted by Act 25 of 2005. This provision has got a laudable object behind it, particularly from the point of view of granting bail. This provision draws the maximum period for which an undertrial prisoner can be detained. This period has to be reckoned with the custody of the Accused during the investigation, inquiry and trial. We have already explained that the word 'trial' will have to be given an expanded meaning particularly when an appeal or admission is pending. Thus, in a case where an appeal is pending for a longer time, to bring it Under Section 436A, the period of incarceration in all forms will have to be reckoned, and so also for the revision.

{Para 46}

IN THE SUPREME COURT OF INDIA

Miscellaneous Application No. 1849 of 2021 in Special Leave Petition (Crl.) No. 5191 of 2021 

 Satender Kumar Antil Vs. Central Bureau of Investigation and Ors.

Hon'ble Judges/Coram:

Sanjay Kishan Kaul and M.M. Sundresh, JJ.

Author: M.M. Sundresh, J.

Decided On: 11.07.2022

Citation: MANU/SC/0851/2022.

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