Ramayan Singh vs. State of Uttar Pradesh (Supreme Court, 19 April 2024)
Background
The case stemmed from a violent incident on January 2, 2022, when Ramayan Singh (the complainant), his uncle Jitendra Singh (the deceased), and their driver were attacked while returning from Bankati Bazar. The accused, including Vivek Pal @ Vikki Pal and Punit Pal, allegedly stopped their vehicle, verbally abused them, shattered the car windows with iron rods, dragged Jitendra Singh out, and brutally assaulted him with iron rods, hockey sticks, and bats, resulting in his death. The FIR charged the accused under multiple sections of the Indian Penal Code, including 147, 148, 149 (rioting), 323 (hurt), 504, 506 (criminal intimidation), 427 (mischief), 394 (robbery), 411 (dishonestly receiving stolen property), 302 (murder), and 120-B (criminal conspiracy).
High Court Proceedings
The Allahabad High Court granted bail to Vivek Pal @ Vikki Pal (Respondent No. 2) and, later, to co-accused Punit Pal under Section 439 CrPC, despite the gravity of the charges. The complainant appealed to the Supreme Court, arguing that the High Court failed to consider the seriousness of the crime, the accused’s conduct, and the societal impact. The State of Uttar Pradesh supported the complainant, highlighting that both accused were also being prosecuted under the Uttar Pradesh Gangsters and Anti-Social Activities (Prevention) Act, 1986, and that there were allegations of intimidation against witnesses during the trial.
Supreme Court’s Analysis
The Supreme Court, led by Justices Sanjay Karol and Satish Chandra Sharma, scrutinized the High Court’s exercise of bail discretion. The Court reiterated that while bail is a discretionary power, it must not be exercised arbitrarily or injudiciously, especially in cases involving serious crimes and broad daylight murders with significant societal impact. The Court cited the parameters laid down in Prasanta Kumar Sarkar v. Ashis Chatterjee (2010), emphasizing that factors such as the prima facie case, gravity of the accusation, severity of punishment, and conduct of the accused must be considered.
The Court found that the High Court had overlooked the seriousness of the crime, the alleged attempts by the accused to intimidate witnesses, and the disruption caused to the local community, including the closure of a market for ten days due to the accused’s influence. The Supreme Court held that the discretion to grant bail had been exercised improperly in this case.
Judgment and Outcome
The Supreme Court set aside the High Court’s orders granting bail to Vivek Pal @ Vikki Pal and Punit Pal, cancelled their bail bonds, and directed that they be taken into custody forthwith. The judgment reinforced the principle that bail in serious offences must be granted only after careful judicial scrutiny and consideration of all relevant factors, including the broader impact on society.
Significance
This decision reaffirms that courts must exercise caution and adhere to established legal principles when granting bail in cases involving grave offences, ensuring that public confidence in the justice system is maintained and that the process is not undermined by arbitrary or capricious decisions.
Citation: Ramayan Singh v. State of Uttar Pradesh & Anr., [2024] 4 S.C.R. 686 : 2024 INSC 323, Supreme Court of India, Criminal Appeal No. 2168 of 2024, Judgment dated 19 April 2024.
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