Wednesday, 4 December 2024

Delhi High Court denies anticipatory bail to man booked for sexually harassing minor on Instagram

 


 It is settled law that the custodial interrogation is qualitatively more elicitation oriented than questioning a suspect who is well ensconced with a favourable order under Section 482 of the Bharatiya Nagarik Suraksha Sanhita (BNSS’) [State v.

Anil Sharma : (1997) 7 SCC 187]. Granting anticipatory bail to

the applicant would undoubtedly impede further investigation.

An order of bail cannot be granted in a routine manner so as to

allow the applicant to use the same as a shield. {Para 15 }

16. This court has perused the case diary and gone through the

statements of the victim, mother of the victim and co-accused -

Sameer. There are materials in the case diary implicating the

applicant in the allegations which the police are investigating.

The allegations against the applicant are of a grave and serious

nature, involving the exploitation and sexual abuse of a minor

girl. The applicant is accused of coercing the victim into

engaging in sexually explicit acts over video calls, recording the

same without her consent, and using these recordings to

blackmail her repeatedly. Such acts not only violate the personal

dignity and privacy of the victim but also constitute serious

offences under the BNS and the POCSO Act.

17. The allegations against the applicant points towards the

exploitation of a child by coercing and blackmailing her for

pornographic purposes. The alleged recording and sharing of

explicit material involving the minor victim is a grave offence.

19. The present case underscores the increasing misuse of

social media and technology to exploit and intimidate vulnerable

individuals, particularly minors. In light of the allegations,

perusal of the statement of the victim and co-accused Sameer,

this Court finds that granting pre-arrest bail would set an

inappropriate precedent and undermine the societal interest in

safeguarding children from such reprehensible acts.

20. The actions of the applicant exemplify the disturbing trend

of exploiting the anonymity and reach of social media platforms

to perpetrate sexual crimes against minors. This Court cannot

ignore the broader societal implications of such acts and the

urgent need to send a strong message against the misuse of

technology.

21. Considering that the present case involves electronic

gadgets and electronic evidence, the task of the Investigating

Agency seems arduous and they need to be given a fair play in

the joints to investigate the matter in the manner they deem

appropriate. The matter requires thorough investigation which

ought not to be curtailed by passing an order granting pre-arrest

bail.

22. The relief of pre-arrest bail is a legal safeguard intended to protect individuals from potential misuse of power of arrest. It plays a crucial tool in preventing harassment and unjust detention of innocent persons. However, the court must carefully balance the individual’s right to liberty with the interests of justice. While the presumption of innocence and the right to liberty are fundamental principles of law, they must be considered in conjunction with the gravity of the offence, its societal impact, and the need for a comprehensive and unobstructed investigation.

23. Considering the material on record, it cannot be held at this stage that the investigation is being carried out with the intention to injure or humiliate the applicant and does not indicate false implication of the applicant. The nature and gravity of allegations are serious. Specific allegations have been made regarding the applicant’s alleged involvement in the commission of the offence.

24. The material presented by the prosecution establishes a prima facie involvement of the applicant. Granting pre-arrest bail to the applicant would undoubtedly impede further investigation.

25. The present application is accordingly dismissed.

 IN THE HIGH COURT OF DELHI AT NEW DELHI

  BAIL APPLN. 4440/2024

SAIFUL KHAN  Vs STATE & ANR. 

CORAM:

HON'BLE MR. JUSTICE AMIT MAHAJAN

AMIT MAHAJAN, J. (Oral).

Date of Decision: 03rd December, 2024

CRL.M.A. 36333/2024 (exemption form filing certified copy of

annexures and true typed copy of dim annexures and also

maintaining 4 inch margin on the left side of the annexures)

1. Exemption allowed, subject to all just exceptions.

2. The application stands disposed of.


3. The present application is filed seeking pre-arrest bail in

FIR No. 600/2024 dated 30.08.2024, registered at Police Station

Nand Nagri, for offences under Sections 354(D)/506 of the

Indian Penal Code, 1860 (IPC) and Section 12 of the Protection

of Children from Sexual Offenses Act, 2012 (POCSO).

4. Briefly stated, the FIR in the present case was registered

based on the complaint filed by the complainant/victim, a 15-

year-old minor girl studying in Class XI, alleging that she was

subjected to severe harassment, blackmail, and sexual

exploitation by the applicant, Saiful Khan, and the co-accused,

Sameer. The complainant alleged that in November 2022, the co-accused Sameer had begun following her on her way to school

and persistently asked her to be his friend. Upon her refusal, the

victim informed her mother, who approached Sameer’s family,

leading to a temporary cessation of his actions. However, in

August 2023, Sameer resumed following the victim and, in

November 2023, contacted her via Instagram, claiming that he

sought a “normal friendship.” The victim reluctantly started

communicating with him, and during their interactions, she

shared a few photographs of herself, and in all of them she was

clothed.

5. It is alleged that in May 2024, the applicant contacted the

victim on Instagram, introducing himself as Sameer’s friend.

Despite her refusal to communicate, Saiful sent the victim a

photograph where she was seen nude and threatened to make it

viral unless she complied with his demands. Fearing public

humiliation, the victim was coerced into communicating with

Saiful through Instagram video calls. During these calls, Saiful

forced the complainant to remove her clothes, which he recorded.

He subsequently used these recordings to repeatedly blackmail

her. She alleged that in June 2024, the applicant shared one of the

victim’s explicit photographs with co-accused - Sameer.

Encouraged by this, co-accused - Sameer also began threatening

the victim, demanding that she engage in similar video calls with

him. Succumbing to the coercion, the victim complied, and co-accused - Sameer recorded these calls as well. The victim further

alleged that both accused persons continuously threatened to

make the complainant’s photographs and videos public.

6. The learned counsel for the applicant submits that the

applicant has been falsely implicated in the present case. He

submits that the allegations made by the victim are fabricated and

intended to malign the applicant without any substantive

evidence.

7. He submits that the applicant is a young individual with no

criminal antecedents. He emphasized that the applicant had left

India for employment in Riyadh, Saudi Arabia, in early

September 2024, as evidenced by his visa and travel documents.

He returned to India voluntarily in November 2024 upon learning

about the present FIR. This demonstrates his bona fide to

cooperate with the investigation rather than evade the process of

law.

8. The learned counsel pointed out that the victim herself

admitted that she has never met the applicant in person. The

interactions were allegedly limited to online platforms, which,

according to the counsel, does not warrant the stringent measures

being invoked against the applicant.

9. He submits that the applicant is a young individual with a

promising future. Incarceration at this stage would irreparably

harm his career and prospects.

10. Per Contra, the learned Additional Public Prosecutor

(APP) for the State opposes the grant of any relief to the

applicants. He submits that the allegations against the applicant

are serious in nature. He submits that the learned Additional

Sessions Judge rightly rejected the bail of the applicant, and that

there is no ground to interfere with the same.

11. The learned APP submits that custodial interrogation of

the applicant is essential to recover the electronic devices

allegedly used in the offence, ascertain the extent of the offenses,

and trace the potential circulation of explicit material.

12. The State expressed concerns over the likelihood of the

applicant attempting to intimidate the victim or influence

witnesses if released on bail. The nature of the threats previously

made by the applicant indicates a significant risk of obstruction

in the course of justice.

13. It is to be kept in mind that the investigation is currently at

a nascent stage. The considerations governing the grant of prearrest bail are materially different than those to be considered

while adjudicating application for grant of regular bail, as in the

latter case, the accused is already under arrest and substantial

investigation is carried out by the investigating agency.

14. It is trite law that the power to grant a pre-arrest bail under

Section 482 of the BNSS is extraordinary in nature and is to be

exercised sparingly. Thus, pre-arrest bail cannot be granted in a

routine manner. The Hon’ble Apex Court, in the case of State of

A.P. v. Bimal Krishna Kundu : (1997) 8 SCC 104, held as

under:

“8. A three-Judge Bench of this Court has stated

in Pokar Ram v. State of Rajasthan [(1985) 2 SCC

597 : 1985 SCC (Cri) 297 : AIR 1985 SC 969] : (SCC

p. 600, para 5)

“5. Relevant considerations governing the

court's decision in granting anticipatory bail

under Section 438 are materially different from

those when an application for bail by a person

who is arrested in the course of investigation

as also by a person who is convicted and his

appeal is pending before the higher court and

bail is sought during the pendency of the

appeal.”

9. Similar observations have been made by us in a

recent judgment in State v. Anil Sharma [(1997) 7

SCC 187 : 1997 SCC (Cri) 1039 : JT (1997) 7 SC

651] : (SCC pp. 189-90, para 8)

“The consideration which should weigh with

the Court while dealing with a request for

anticipatory bail need not be the same as for

an application to release on bail after arrest.”

xxxx xxxx xxxx

12. We are strongly of the opinion that this is not a

case for exercising the discretion under Section 438 in

favour of granting anticipatory bail to the

respondents. It is disquieting that implications of

arming the respondents, when they are pitted against

this sort of allegations involving well-orchestrated

conspiracy, with a pre-arrest bail order, though

subject to some conditions, have not been taken into

account by the learned Single Judge. We have

absolutely no doubt that if the respondents are

equipped with such an order before they are

interrogated by the police it would greatly harm the

investigation and would impede the prospects of

unearthing all the ramifications involved in the

conspiracy. Public interest also would suffer as a

consequence. Having apprised himself of the nature

and seriousness of the criminal conspiracy and the

adverse impact of it on “the career of millions of

students”, learned Single Judge should not have

persuaded himself to exercise the discretion which

Parliament had very thoughtfully conferred on the

Sessions Judges and the High Courts through Section

438 of the Code, by favouring the respondents with

such a pre-arrest bail order.”


15. It is settled law that the custodial interrogation is

qualitatively more elicitation oriented than questioning a suspect

who is well ensconced with a favourable order under Section 482

of the Bharatiya Nagarik Suraksha Sanhita (BNSS’) [State v.

Anil Sharma : (1997) 7 SCC 187]. Granting anticipatory bail to

the applicant would undoubtedly impede further investigation.

An order of bail cannot be granted in a routine manner so as to

allow the applicant to use the same as a shield.

16. This court has perused the case diary and gone through the

statements of the victim, mother of the victim and co-accused -

Sameer. There are materials in the case diary implicating the

applicant in the allegations which the police are investigating.

The allegations against the applicant are of a grave and serious

nature, involving the exploitation and sexual abuse of a minor

girl. The applicant is accused of coercing the victim into

engaging in sexually explicit acts over video calls, recording the

same without her consent, and using these recordings to

blackmail her repeatedly. Such acts not only violate the personal

dignity and privacy of the victim but also constitute serious

offences under the BNS and the POCSO Act.

17. The allegations against the applicant points towards the

exploitation of a child by coercing and blackmailing her for

pornographic purposes. The alleged recording and sharing of

explicit material involving the minor victim is a grave offence.

19. The present case underscores the increasing misuse of

social media and technology to exploit and intimidate vulnerable

individuals, particularly minors. In light of the allegations,

perusal of the statement of the victim and co-accused Sameer,

this Court finds that granting pre-arrest bail would set an

inappropriate precedent and undermine the societal interest in

safeguarding children from such reprehensible acts.

20. The actions of the applicant exemplify the disturbing trend

of exploiting the anonymity and reach of social media platforms

to perpetrate sexual crimes against minors. This Court cannot

ignore the broader societal implications of such acts and the

urgent need to send a strong message against the misuse of

technology.

21. Considering that the present case involves electronic

gadgets and electronic evidence, the task of the Investigating

Agency seems arduous and they need to be given a fair play in

the joints to investigate the matter in the manner they deem

appropriate. The matter requires thorough investigation which

ought not to be curtailed by passing an order granting pre-arrest

bail.

22. The relief of pre-arrest bail is a legal safeguard intended to

protect individuals from potential misuse of power of arrest. It

plays a crucial tool in preventing harassment and unjust detention

of innocent persons. However, the court must carefully balance

the individual’s right to liberty with the interests of justice. While

the presumption of innocence and the right to liberty are

fundamental principles of law, they must be considered in

conjunction with the gravity of the offence, its societal impact,

and the need for a comprehensive and unobstructed investigation.

23. Considering the material on record, it cannot be held at this

stage that the investigation is being carried out with the intention

to injure or humiliate the applicant and does not indicate false

implication of the applicant. The nature and gravity of allegations

are serious. Specific allegations have been made regarding the

applicant’s alleged involvement in the commission of the

offence.

24. The material presented by the prosecution establishes a

prima facie involvement of the applicant. Granting pre-arrest bail

to the applicant would undoubtedly impede further investigation.

25. The present application is accordingly dismissed.

26. It is clarified that any observations made in the present

order are for the purpose of deciding the present bail application

and should not influence the outcome of the trial and also not be

taken as an expression of opinion on the merits of the case.

AMIT MAHAJAN, J

DECEMBER 3, 2024

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