Manno Lal Jaiswal vs. State of Uttar Pradesh: Supreme Court Cancels Bail in Murder Case

The case of Manno Lal Jaiswal vs. State of Uttar Pradesh & Anr. revolves around the grant of bail in a murder case. The Supreme Court examined whether the Allahabad High Court had correctly granted bail to the accused in a case involving charges under Sections 147, 148, 149, 323, 504, 506, 302, and 307 of the Indian Penal Code (IPC). The Court found serious errors in the High Court’s decision and ultimately canceled the bail, directing the accused to surrender.

Background of the Case

The appellant, Manno Lal Jaiswal, is the father of the deceased, Sumit Jaiswal. He filed an FIR at Barhaj Police Station, District Deoria, alleging that a group of accused attacked his son with swords, hockey sticks, rods, and other weapons, leading to his death.

The accused were initially denied bail by the Sessions Court after it reviewed the case diary and evidence. However, they approached the Allahabad High Court, which granted them bail in 2020. This led the appellant to file a plea before the Supreme Court, arguing that the bail was granted based on incorrect facts.

Petitioner’s Arguments

The appellant, represented by Vijay Kumar Shukla, argued:

The High Court wrongly observed that the accused were not named in the FIR, when in fact, their names were included from the beginning.
The High Court stated that the witness statements under Section 161 CrPC were recorded after a delay of 20 days, which was factually incorrect. The statements were recorded on the same day as the incident.
The accused had a common intention and attacked the deceased with deadly weapons.
The Sessions Court had already denied bail after considering the evidence, and the High Court did not properly assess the case before granting bail.
Granting bail to the accused in such a serious case undermined the justice system.

Respondent’s Arguments

The accused, represented by Krishna M. Singh, countered:

The accused had been in judicial custody since 2019 and 2020.
Their role in the crime was minimal, as they allegedly used a cricket wicket and not a deadly weapon.
There was no direct evidence that they inflicted fatal injuries on the deceased.
They had no previous criminal record and should be allowed bail.

Key Observations of the Supreme Court

A bench comprising Justice M.R. Shah and Justice Sanjiv Khanna made the following observations:

The accused were clearly named in the FIR, contradicting the High Court’s findings.
Witness statements were recorded on the same day as the incident, not after 20 days.
The accused were part of an unlawful assembly and shared a common intention to commit the crime.
The High Court had not considered the gravity of the offense while granting bail.
The bail was granted based on incorrect facts and without proper reasoning.

Final Judgment

The Supreme Court ruled:

The bail granted by the Allahabad High Court was canceled.
The accused were directed to surrender immediately.
The case would proceed on its merits, and the trial court was instructed to continue proceedings.

Implications of the Judgment

The ruling has several important legal implications:

Strict Bail Conditions: Courts must ensure proper reasoning when granting bail in serious criminal cases.
Accountability in Judicial Decisions: High Courts must verify facts before granting bail to accused persons in murder cases.
Reinforcement of Legal Precedents: The ruling aligns with previous Supreme Court decisions emphasizing judicial discretion in bail matters.
Ensuring Fair Trial: The cancellation of bail ensures that the accused remain in judicial custody, preventing any influence on the trial.

Conclusion

The case of Manno Lal Jaiswal vs. State of Uttar Pradesh highlights the necessity for courts to exercise caution while granting bail in serious criminal cases. The Supreme Court’s intervention ensured that the accused were not granted undue liberty based on incorrect facts. The ruling reinforces the principle that justice should be based on facts and evidence rather than procedural errors.

Petitioner Name: Manno Lal Jaiswal.
Respondent Name: State of Uttar Pradesh & Anr..
Judgment By: Justice M.R. Shah, Justice Sanjiv Khanna.
Place Of Incident: Deoria, Uttar Pradesh.
Judgment Date: 25-01-2022.

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