Sunday, 9 November 2025

Supreme Court: The court should not release accused on anticipatory bail for offence U/S 302 of IPC if there are specific averments against them in FIR

As for the matter with regard to grant of

anticipatory bail to the respondents-accused, the

law has been enunciated by this Court in Sushila

Aggarwal v. State (NCT of Delhi) (2020) 5 SCC 1, wherein it

was held that the following factors have to be

considered while granting the relief of

anticipatory bail, which are as follows:

“92.4. Courts ought to be

generally guided by

considerations such as the

nature and gravity of the

offences, the role attributed to

the applicant, and the facts of the

case, while considering whether

to grant anticipatory bail, or

refuse it. Whether to grant or not

is a matter of discretion; equally

whether and if so, what kind of

special conditions are to be

imposed (or not imposed) are

dependent on facts of the case,

and subject to the discretion of

the court.” {Para 12}

13. Considering the above laid law and the fact that

there are specific averments in the FIR against all

the accused persons including the respondents

herein that all of them had set the deceased on

fire with an intention to kill him, we fail to

understand as to how the High Court had

granted relief of anticipatory bail to the

respondents in an offence under Section 302 of

the IPC. The High Court has erred in granting the

relief in a cryptic and mechanical manner

without considering the materials available on

record including the chargesheet which stated

that the case has been found true against all the

accused persons of such a heinous offence of

murder by pouring kerosene oil and setting the

deceased on fire.

REPORTABLE

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

CRIMINAL APPEAL NO. OF 2024

SHAMBHU DEBNATH Vs THE STATE OF

BIHAR & ORS. 

Author: VIKRAM NATH, J.

Citation:  2024 INSC 1032.

Dated: DECEMBER 20, 2024

1. Leave granted.

2. The instant appeal has been preferred by the

complainant against the grant of anticipatory

bail to respondents nos. 2 to 4 by the High Court

of Judicature at Patna in Criminal Miscellaneous

No. 28525 of 2023, vide order dated 25.07.2023.

3. Brief facts of the present case are that the

appellant herein had submitted a written

application on 13.01.2023 before S.H.O., Mufasil

alleging that on the same day at around 7.00 pm,

he came out of the house hearing the ruckus and

saw that the body of his 20-year-old nephew,

Mukesh Kumar, was ablaze the fire. When the

appellant asked his injured nephew, he was told

that Sindhu Devnath, Sanjit Devnath, Ratan

Devnath (respondent no. 2 herein), Lalita Devi

(respondent no. 3 herein), Sunil Devnath and

Rina Devi (respondent no. 4 herein) had caught

hold of him, whereby Sindhu Devnath told him

that the appellant’s nephew loved his daughter

and all of them started beating and abusing him.

Further, it was stated that all of the accused

persons, with an intention to kill, poured

kerosene oil over the appellant’s nephew and set

his body on fire. As such, Motihari Mufasil P.S.

Case No. 28 of 2023 was lodged for the offences

punishable under sections 341, 323, 307, 504

and 34 of the Indian Penal Code, 18601.

4. In the course of the treatment, the nephew of the

appellant succumbed to the burn injuries on

1 “IPC”, hereinafter.

17.01.2023 and consequently, Section 302 of the

IPC was added.

5. Apprehending their arrest in connection with the

above-mentioned FIR, respondent nos. 2 to 4

preferred an application seeking anticipatory bail

before the Sessions Court which was rejected by

the Court of Additional District and Sessions

Judge-22, East Champaran, Motihari, vide its

order dated 24.03.2023. Subsequently, the

Police submitted chargesheet against one of the

accused persons namely Sindhu Devnath,

wherein it was also categorically mentioned that

from the investigation so far, the case has been

found true against all the accused persons

named in the FIR and subsidiary investigation of

the case was still pending then.

6. Aggrieved by the rejection of anticipatory bail by

the Court of Additional District and Sessions

Judge, respondent nos. 2 to 4 preferred an

application seeking anticipatory bail before the

Patna High Court. The High Court, vide the

impugned order, allowed the application of

respondent nos. 2 to 4 and granted them

anticipatory bail.

7. The appellant-complainant is aggrieved by the

order dated 25.07.2023 and has submitted that

such a grant of anticipatory bail by the High

Court was unwarranted.

8. Notices in the instant matter were issued on

12.01.2024. However, despite service of notice,

respondent nos. 2 to 4 had initially failed to put

in appearance. Eventually, the respondents did

put in appearance and sought time to file

counter-affidavit which was recorded in the order

dated 04.11.2024. However, on 25.11.2024, we

were apprised by Mr. Amitava Poddar, learned

counsel appearing for the respondent-accused

nos. 2 to 4 that the accused persons have

instructed him not to appear on their behalf

anymore. Therefore, we had directed for nonbailable

warrants to be issued against

respondent nos. 2 to 4 to ensure that they are

taken into custody and be produced before this

Court on the next date.


9. Pursuant to the abovementioned order dated

25.11.2024, respondent nos. 2 to 4 are present

in the Court today.

10. Mr. Arup Banerjee, Advocate-on-Record

represents respondent nos. 2 to 4. Respondent

no. 4 has been produced before us by Sub

Inspector Mr. Sudhir Tiwari, East Champaran,

Bihar.

11. As the respondent no. 4 has been produced in

custody and such non-bailable warrants were

issued only for the purpose of appearance since

the respondents were evading to enter

appearance before this Court, she was directed

to be released.

12. As for the matter with regard to grant of

anticipatory bail to the respondents-accused, the

law has been enunciated by this Court in Sushila

Aggarwal v. State (NCT of Delhi)2, wherein it

was held that the following factors have to be

2 (2020) 5 SCC 1

considered while granting the relief of

anticipatory bail, which are as follows:

“92.4. Courts ought to be

generally guided by

considerations such as the

nature and gravity of the

offences, the role attributed to

the applicant, and the facts of the

case, while considering whether

to grant anticipatory bail, or

refuse it. Whether to grant or not

is a matter of discretion; equally

whether and if so, what kind of

special conditions are to be

imposed (or not imposed) are

dependent on facts of the case,

and subject to the discretion of

the court.”

13. Considering the above laid law and the fact that

there are specific averments in the FIR against all

the accused persons including the respondents

herein that all of them had set the deceased on

fire with an intention to kill him, we fail to

understand as to how the High Court had

granted relief of anticipatory bail to the

respondents in an offence under Section 302 of

the IPC. The High Court has erred in granting the

relief in a cryptic and mechanical manner

without considering the materials available on

record including the chargesheet which stated

that the case has been found true against all the

accused persons of such a heinous offence of

murder by pouring kerosene oil and setting the

deceased on fire.

14. Therefore, in the facts and circumstances of the

case, we do not deem it appropriate that

anticipatory bail should be granted to the

respondents-accused.

15. Accordingly, the instant appeal is allowed. The

impugned order of the High Court dated

25.07.2023 is set aside. Respondent nos. 2 to 4

are directed to surrender before the Trial Court

within four weeks from today and they are

granted liberty to file an application for regular

bail, which if filed would be considered as per law

on its own merits uninfluenced by any

observations made in this judgment.


16. Pending application(s), if any, shall stand

disposed of.

……………………………………J.

(VIKRAM NATH)

……………………………………J.

(PRASANNA B. VARALE)

NEW DELHI

DECEMBER 20, 2024

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