Sunday, 22 December 2024

Supreme Court: Bail Should Not Be Granted Ordinarily In Serious Offences Like Rape & Murder Once Trial Starts

 Ordinarily in serious offences like rape, murder, dacoity,

etc., once the trial commences and the prosecution starts

examining its witnesses, the Court be it the Trial Court or the

High Court should be loath in entertaining the bail

application of the accused. {Para 14} 

REPORTABLE

IN THE SUPREME COURT OF INDIA

EXTRAORDINARY APPELLATE JURISDICTION

SPECIAL LEAVE PETITION (CRIMINAL) NO. 13378 OF 2024

X  Vs STATE OF RAJASTHAN & ANR. 

Dated: 27th November, 2024.

Citation: 2024 INSC 909.

1. This petition arises from the impugned order passed by

the High Court of Judicature for Rajasthan at Jodhpur dated

12-02-2024 in SB Criminal Miscellaneous Bail Application

No.1351/2024 by which the bail application filed by the

Respondent No.2 – herein (original accused) came to be

allowed and the Respondent No.2 was ordered to be released

on bail pending trial.


2. It appears from the materials on record that a First

Information Report came to be lodged by the petitioner –

herein dated 18-09-2023 against the Respondent No.2 –

herein and a co-accused for the offence punishable under

Section 376D and Section 342 of the Indian Penal Code. The

FIR bearing No.83/2023 was registered with Police Station

Nachna, District Jaisalmer, Rajasthan.

3. The Respondent No.2 – herein and the co-accused were

arrested in connection with the alleged offence. The

co-accused was ordered to be enlarged on bail long time back.

4. It appears that after the FIR was registered, the statement

of the victim, i.e., the petitioner – herein was recorded by the

Magistrate under Section 164 of the Code of Criminal

Procedure, 1973.

5. Upon conclusion of the investigation, charge-sheet was

filed.

6. The criminal case being committed to the Court of

Sessions came to be registered as the Sessions Case

No.53/2023 pending as on date in the Court of Additional

District and Sessions Judge, Pokaran (Jaisalmer).

7. The prosecution has examined one witness so far.

8. In the midst of the trial, the Respondent No.2 – herein

preferred a bail application before the Trial Court. The Trial

Court declined to release the accused on bail.

9. The accused went before the High Court and prayed for

bail.

10. The High Court took into consideration some

discrepancies emanating between the FIR and the statement

of the victim recorded under Section 164 of the Code. The

High Court was persuaded to release the Respondent No.2 –

herein on bail.

11. Having regard to such discrepancies in the FIR and the

statement recorded under Section 164 of the Code, the

operative part of the impugned order passed by the High

Court reads thus:-

“Para 9. Accordingly, the instant bail application

under Section 439 Cr. P.C is allowed and it is

ordered that the accused-petitioner as amed in

the cause title shall be enlarged on bail provided

he furnishes a personal bond in the sum of

Rs.50,000/- with two sureties of Rs.25,000/-

each to the satisfaction of the learned trial Judge

for his appearance before the court concerned on

all the dates of hearing as and when called upon

to do so.”

12. In such circumstances, referred to above, the petitioner,

i.e., the victim is here before us with the present petition.

13. We have heard the learned counsel appearing for the

petitioner and the learned counsel appearing for the State.

The Respondent No.2 – accused although served with the

notice issued by this Court, yet has chosen not to remain

present before this Court either in-person or through an

Advocate and oppose this petition.

14. Ordinarily in serious offences like rape, murder, dacoity,

etc., once the trial commences and the prosecution starts

examining its witnesses, the Court be it the Trial Court or the

High Court should be loath in entertaining the bail

application of the accused.

15. Over a period of time, we have noticed two things, i.e., (i)

either bail is granted after the charge is framed and just

before the victim is to be examined by the prosecution before

the trial court, or (ii) bail is granted once the recording of the

oral evidence of the victim is complete by looking into some

discrepancies here or there in the deposition and thereby

testing the credibility of the victim.

16. We are of the view that the aforesaid is not a correct

practice that the Courts below should adopt. Once the trial

commences, it should be allowed to reach to its final

conclusion which may either result in the conviction of the

accused or acquittal of the accused. The moment the High

Court exercises its discretion in favour of the accused and

orders release of the accused on bail by looking into the

deposition of the victim, it will have its own impact on the

pending trial when it comes to appreciating the oral evidence

of the victim. It is only in the event if the trial gets unduly

delayed and that too for no fault on the part of the accused,

the Court may be justified in ordering his release on bail on

the ground that right of the accused to have a speedy trial

has been infringed.

17. In the case on hand, the victim is yet to be examined. Her

mother who, according to the case of the prosecution, is an

eye-witness has also not been examined so far. The High

Court seems to have looked into few discrepancies in the FIR

compared to the statement of victim recorded under Section

164 of the Code. This could not have been a good ground to

exercise discretion in favour of an accused in a serious

offence like rape.


18. However, we are of the view that now at this point of time,

we should not disturb the impugned order passed by the High

Court. At the same time, we should impose appropriate

conditions so as to ensure that the Respondent No.2 – herein

and the co-accused do not influence the prosecution

witnesses or try to tamper with the evidence in any manner.

Even while enlarging the accused on bail, the High Court

should have been conscious of this fact. The High Court has

thought fit to only ask the Respondent No.2 - accused –

herein to furnish solvent surety of an amount of Rs. 50,000/-

without imposing any appropriate conditions.

19. We wonder if the High Court was made aware of the fact

that the victim and her mother as well as both the accused

are residing in the very same village viz. Magriyan Ki Dhani

Satyaya, District Jaisalmer, Rajasthan.

20. In such circumstances, without disturbing the order of

bail passed by the High Court, we direct that the Respondent

No.2 – herein shall not enter the said village till the

completion of the trial. As we have asked the respondent

No.2 – accused not to enter the village, he shall furnish

address of his new residence to the investigating officer

attached with the concerned police station. The Respondent

No.2 shall not try to influence any of the prosecution

witnesses in any manner or directly or indirectly try to

contact the victim and her family.

21. Having regard to the nature of the alleged crime, it will be

in the fitness of things if the Trial Court gives some priority to

the Sessions Case No.53/2023 and try to dispose it of within

a period of three months from today.

22. We clarify that what has been observed by us in this

order are just prima facie observations and shall not be

considered as an expression of any final opinion as regards

the guilt or innocence of the accused.

23. The Special Leave Petition is disposed of in above terms.

24. Pending applications, if any, also stand disposed of.

…………………………………J.

( J.B. Pardiwala)

………………………………..J.

(R. Mahadevan)

New Delhi;

27th November, 2024

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