Sunday, 9 November 2025

Supreme Court: Bail Cannot Be Granted To Murder Accused Merely Because No Overt Act Is Attributed To Him In FIR

 It can also safely be said that merely because no overt act was attributed to the respondent accused in the First Information Report the same cannot be the sole consideration for grant of bail to these respondents in a serious offence under Section 302 of IPC. Time and again, it is observed by this Court that First Information Report is not an encyclopaedia of facts. An FIR is a starter point to set the investigation in motion and subsequently, the investigating agency collects the necessary material in the course of investigation so as to unearth the real offenders. {Para 16}

Non-Reportable

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL NO._2573_OF 2025

AASHISH YADAV Vs  YASHPAL & ORS.

Author: PRASANNA B. VARALE, J.

Citation:  2025 INSC 666.

1. Leave granted

2. The present appeal arises from the Impugned Order dated

23/08/2024 passed by the High Court of Judicature for

Rajasthan, Jaipur Bench in Crl. Misc. Bail Application No.6946 of

2024, wherein the High Court allowed the bail application of the

accused respondents on basis of parity observing that the other

two co-accused in the case had already been granted bail on the

same set of allegations. Aggrieved by the same, the Petitioner has

preferred the present appeal.

3. The brief facts leading to the present appeal are as under-

It is the case of the Prosecution that on 28.11.2023 during a

marriage procession, the accused respondents got into a fight

with the victim, Aman Yadav, during which one person named

Vicky @ Kartoos fired seven rounds of bullets out of which one hit

the victim killing him, and the remaining bullets hit two other

people, Vikash and Naveen at the procession gravely injuring

them. Immediately after, the accused respondents and Vicky @

Kartoos fled the location in a car. Following the incident, FIR

No. 489/2023 was registered on 29.11.2023 at Kotkasim Police

Station, District Khairthlal, Tijara, Rajasthan under Sections

143, 341, 323, 307, 302 the Indian Penal Code, 18601 and

Section 3 and 25 of the Arms Act, 19592 wherein it was alleged

that in furtherance of an existing enmity with the victim, the

accused respondents hired the contract Killer, Vicky @ Kartoos,

to kill the victim and that he was killed in a planned and pre-

1 (hereinafter referred to as ‘IPC’)

2 (hereinafter referred to as ‘Arms Act’)


meditated manner in the middle of a marriage procession. It is

also mentioned in the FIR that Yashpal, Raman and their family

had been harbouring a grudge against Aman Yadav ever since an

argument took place at a well worship ceremony in the village on

19.11.2023.

4. During Investigation, three eyewitnesses were examined out

of which two were injured by the bullets fired. The statements

given by all the three eyewitnesses were consistent and converged

to confirm the incident. Further, based on the information given

by Vickky @ Kartoos in his statement under Section 27 of the

Indian Evidence Act,1872 the pistol/weapon from which shots

were fired was recovered from the house of accused respondent

No. 1. He also identified the location where the test shots were

fired. Chargesheet was filed after completion of the investigation

under Sections 341, 323, 307, 302, 120B, 147, 148, 149 of IPC

and Sections 3, 25, 5, 27 of Arms Act before the Learned Trial

Court on 27.02.2024. The chargesheet kept investigation against

the Accused Respondents pending as they were absconding. In

the chargesheet reference to the accused respondents was made

as absconding accused.


5. On 04.03.2024, one of the co-accused, Kulwant, was

granted bail by the High Court observing that the main accused

in the matter are Yashpal, Raman and Vicky @ Kartoos. Another

co-accused Om Prakash was also granted bail by the High Court

on 19.03.2024 on the ground that another co-accused who is not

a main accused has been granted bail. Following the two bail

orders enlarging bail to the co-accused, the accused respondents

moved S.B Criminal Miscellaneous Bail Application No.

4459/2024 and S.B Criminal Miscellaneous Bail Application

No.4460/2024 which was dismissed by the High Court vide order

dated 29.04.2024 with liberty to surrender before the Ld. Trial

Court. Subsequently, the accused respondents surrendered

before the Trial Court on 14.5.2024 and were taken into custody.

6. After surrendering, first Bail Application No. 221.2024 was

moved by the accused respondents before the Trial Court which

was dismissed vide order dt. 29.05.2024. Supplementary

chargesheet No. 2 was filed under Sections 341, 323, 307, 302,

120B, 147, 148, 149 of IPC and Sections 3, 25, 5, 27 of Arms

Act on 12.08.2024 wherein it was concluded that the accused

respondents are the mastermind behind conspiracy to kill the

victim.


7. A second Bail Application No. 6946/2024 was moved by the

accused respondents before the Rajasthan High Court, Jaipur

Bench where the High Court vide order dt. 23.08.2024 allowed

the bail applications of the accused respondents observing that -

“5. Considering the arguments put forward by the learned

counsel for the petitioners and looking to the fact that injured

Vikas and Naveen, in their statements recorded under Section

161 Cr.P.C. have levelled allegations of causing fire arm

injuries against Vicky @ Kartoos. The general omnibus

allegations have been levelled against the petitioners and the

co-accused Sandeep and Om Prakash, whom indulgence of

bail has already been granted by this Court. Looking to the

fact that the case of the petitioners is of Par with them and

they are in custody from the date of their arrest and after

investigation, charge-sheet has been filed and trial will take

its own time to conclude and without expressing any opinion

on merits and demerits of the case, I deem it just and

appropriate to grant indulgence of bail to the petitioners under

Section 439 Cr.P.C.

6. Accordingly, this bail application under Section 439 Cr.P.C.

is allowed and it is ordered that accused- petitioners Yashpal

S/o Deepak and Raman S/o Sanjay who are arrested in

connection with aforementioned FIR, may be released on bail;

provided they both furnishes a personal bond of Rs.50,000/-

with two surety bonds of Rs.25,000/- each to the satisfaction

of learned trial Court with the stipulation to appear before that

Court on all dates of hearing and as and when called upon to

do so.”

8. Aggrieved by the order, the Petitioner has filed the present

appeal before us.


Submissions

9. The counsel for the petitioner has contended that the High

Court had earlier granted bail to the co-accused Kulwant,

Sandeep and Omprakash on the ground that they were not the

main accused who are the accused respondents herein. The

counsel submitted that the High Court now cannot grant bail to

the main accused respondents observing that the co-accused

have been granted bail in the matter already. It is submitted that

the case of respondents is very different from that of the coaccused.

The accused respondents are the mastermind behind

the conspiracy to kill the victim and the same is established from

the fact that on 19.11.2023 and 20.11.2023 there was serious

fight between respondent accused and victim in which

respondent accused gave life threats to the victim. It is also

submitted that Vicky @ Kartoos is a contract killer/sharpshooter

and has numerous cases against him and is a history sheeter

wanted in various offences. It is further submitted that the

accused respondents were absconding for six months and thus

there is real apprehension that enlarging them on bail would lead

the accused respondents to abscond again.


10. Per contra, the learned counsel for the respondents have

submitted that there has been a delay in filing the FIR and

additionally the complainant is not an eyewitness to the incident

either. It is submitted that the statements of the eyewitnesses

only indicate that it was a case of sudden fight and was not a

planned conspiracy against anyone. The counsel has further

submitted that there is no material on record to show and

establish common intention of formation of unlawful assembly by

the accused respondents.

Analysis

11. We have heard Learned Counsel for the appellant as well as

Ld. Counsel for the respondent. We have also perused relevant

documents on record and the judgment passed by the High

Court.

12. We do not find any merit in the submission made on behalf

of the accused respondents whose bail application was allowed

holding that no material against the accused person is available

and there is nothing on record to show that the accused

respondents actively participated in the act of firing the bullet.


13. We are of the opinion that the contention that there is no

material to the effect to indicate that they were involved in

hatching the conspiracy is an aspect to be considered by the

court by conducting a full-fledged trial. Sufficient material is

available on record to show that these two accused engaged the

contract killer Vicky @ Kartoos to kill Aman. Even as per the FIR,

it is mentioned that Vicky @ Kartoos is a sharp shooter who used

a firearm to fire bullets during the marriage procession wherein

one victim namely Aman died, and two others namely Vikas and

Naveen were gravely injured whose witness statement has also

been recorded.

14. The submission of the respondents that the accused

persons were only involved in a case of sudden fight cannot be

accepted as the FIR clearly states that the accused were waiting

for some reason so that the hired contract killer could get an

opportunity to shoot the victim. As per the FIR, the sharpshooter

Vicky @ Kartoos and other persons were dancing in the marriage

procession when on a trifle issue they suddenly picked a quarrel

with the victim and the contract killer Vicky @ Kartoos

immediately fired. Also, material on record reveals that before

shooting the victim, the contract killer also conducted a trial

shoot by firing his pistol into the air.

15. On the contrary, we find considerable merit in the

submissions of learned counsel for the appellant that the High

Court committed a serious error in holding and observing that

the case of the respondents is at par with the case of other coaccused

namely Sandeep and Omprakash. In so far as, the order

granting bail to accused Omprakash is concerned, it was

observed in the order dated 19.03.2024 by the learned Judge,

that specific allegations have been assigned to co-accused

Yasphal, Raman and Vicky @ Kartoos. Another consideration

was the age of Omprakash wherein the submission advanced

before the learned Judge in respect of the age of Omprakash was

accepted and it was observed that the petitioner i.e. Omprakash

is an old infirm person of 84 years of age.

16. It can also safely be said that merely because no overt act

was attributed to the respondent accused in the First Information

Report the same cannot be the sole consideration for grant of bail

to these respondents in a serious offence under Section 302 of

IPC. Time and again, it is observed by this Court that First

Information Report is not an encyclopaedia of facts. An FIR is a

starter point to set the investigation in motion and subsequently,

the investigating agency collects the necessary material in the

course of investigation so as to unearth the real offenders. In the

present case also, in the course of investigation, the material

collected by the investigating agency suggested that the

respondent accused persons hatched a conspiracy so as to

eliminate the victim and engaged a contract killer Vicky @

Kartoos to kill the victim Aman. We are unable to accept the

submission of the learned counsel for the respondents that it was

a sudden fight in the marriage procession that led to opening of

firearm and shooting the victim. The material collected by the

investigating agency in the form of statement of witnesses show

that the respondent accused who have engaged a contract killer

Vicky @ Kartoos were waiting for an opportune time so that they

can use the hired contract killer to eliminate victim Aman.

17. It is also reflected from the material, that before the actual

incident of shooting victim Aman, the contract killer Vicky @

Kartoos had opened the firearm for a test firing. The sequence of

events at the incident show that the marriage procession started

and some of the young boys started dancing in the procession.

Aman was also amongst them and while dancing the accused

respondent got into an argument with victim Aman and his

friends. Using this quarrel as an opportunity and as per the plan

hatched by the respondents, the contract killer Vicky @ Kartoos

by using the firearm i.e. pistol, shot victim Aman, resulting in his

death and two other persons, Vikash and Naveen were also

injured. Their statements were also recorded by the investigating

agency. The investigating agency was successful in recovering

the weapon pistol from respondent no. 1. Admittedly, from the

day of arrest till filing of the first chargesheet wherein these

respondent accused were shown as absconding, the respondents

were successful in evading their arrest and subsequently when

the application for grant of bail was rejected these respondents

accused surrendered themselves to the Trial Court and then the

application for grant of bail was filed before the High Court.

18. It was also submitted before the Court that the contract

killer Vicky @ Kartoos is having criminal antecedents and is a

history sheeter. Thus, the apprehension of the complainant, that

the respondent accused, if released on bail may pressurise the

witnesses is not unjustified.


19. The complainant is also justified in making the submission

that as the trial is now in the process and key prosecution

witnesses are yet to be examined, there exists a reasonable

apprehension that if these accused persons are granted bail, then

they may attempt to pressurise or influence the witnesses or even

abscond.

20. The High Court therefore failed to consider these above

grounds and has mechanically passed the order and allowed the

appeal. The order of grant of bail to accused on parity is error

apparent on the face of the record. The High Court failed to

consider that the accused are the main accused in the matter

and cannot be enlarged on bail because the other co-accused

persons have been granted bail. The High Court order granting

bail to the accused respondents is hereby set aside. Accordingly,

the present appeal is allowed.

21. The respondents are directed to surrender themselves to the

concerned authority not later than two weeks from today.

22. Observations, in this judgment are only for the purpose of

setting aside the bail order. The Trial Court is directed to decide

the matter on its own merits, uninfluenced by the observations in

this judgment.

23. Pending application(s), if any, shall stand disposed of.

.................................J.

[K.V. VISWANATHAN]

.….............................J.

[PRASANNA B. VARALE]

NEW DELHI;

MAY 13, 2025.


Print Page

No comments:

Post a Comment