Anticipatory Bail Granted in Rape Case: Supreme Court’s Detailed Analysis

The case of Beerbal Prasad Rajoriya v. State of Madhya Pradesh was brought before the Supreme Court of India, where the petitioner, apprehending arrest, sought anticipatory bail in connection with allegations of rape and criminal intimidation.

The appellant had moved the High Court of Madhya Pradesh for anticipatory bail after being accused under Sections 376(2)(n) and 506 of the Indian Penal Code (IPC). The High Court rejected the plea, leading to this appeal before the Supreme Court.

Background of the Case

The case originated from an FIR No. 0076, dated 10.03.2022, lodged at Police Station Kotwali Sheopur, District Sheopur, Madhya Pradesh. The complainant alleged that the accused had engaged in non-consensual repeated sexual intercourse with her and had intimidated her.

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The appellant, fearing arrest, approached the Supreme Court after the High Court declined to grant him relief.

Supreme Court’s Consideration

On 14.07.2022, the Supreme Court issued an interim order stating:

“Pending further consideration, the petitioner shall not be arrested in connection with First Information Report No.0076 dated 10.03.2022 registered with Police Station Kotwali Sheopur, District Sheopur, Madhya Pradesh, in respect of the offences punishable under Sections 376(2)(n) and 506 of the Indian Penal Code, 1860.”

During the hearing, the petitioner’s counsel, Mr. Fuzail Ahmad Ayyubi, argued that the FIR was filed five months after the alleged incident and that the delay in lodging the complaint raised doubts about its authenticity.

On the other hand, the State’s counsel, Mr. Gopal Jha, contended that the charges were serious and that anticipatory bail should not be granted.

Final Judgment

The Supreme Court found that the facts and circumstances of the case justified anticipatory bail. The Court, therefore, made its interim relief order absolute and laid down the following conditions:

• The appellant shall be released on bail in the event of his arrest upon furnishing a cash security of Rs.50,000/- along with two like sureties.
• The appellant must cooperate fully with the investigation.
• The appellant must appear whenever required by the investigating officer.
• The appellant shall not attempt to influence the investigation or the trial proceedings.

With these conditions, the Supreme Court allowed the appeal.

Significance of the Judgment

The case highlights the importance of considering delays in lodging FIRs, especially in cases involving serious allegations. The judgment reinforces the principle that anticipatory bail should be granted when there are reasonable grounds to believe that an individual may be falsely implicated.

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The ruling also sets a precedent on the necessity of safeguarding personal liberty while ensuring cooperation with the investigative process.

Petitioner Name: Beerbal Prasad Rajoriya.
Respondent Name: State of Madhya Pradesh.
Judgment By: Justice Uday Umesh Lalit, Justice S. Ravindra Bhat.
Place Of Incident: Sheopur, Madhya Pradesh.
Judgment Date: 05-09-2022.

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