Omprakash vs. State of Madhya Pradesh: Supreme Court Grants Bail on Grounds of Parity

The case of Omprakash @ Manta vs. The State of Madhya Pradesh revolves around the issue of parity in bail. The Supreme Court of India, in its judgment dated 1st October 2018, granted bail to the appellant, Omprakash, whose sentence had not been suspended while the same relief had been granted to co-accused individuals convicted alongside him.

Case Background

The appellant, Omprakash, was one of several accused in a criminal case. After his conviction and sentencing, he approached the Madhya Pradesh High Court, seeking a suspension of his sentence while his appeal was pending. The High Court, however, refused to grant him relief, even though other co-accused (Accused Nos. 2, 3, and 4) had already been granted suspension of sentence and bail. This led the appellant to approach the Supreme Court.

Arguments Presented by the Petitioner

The petitioner, Omprakash, through his counsel, argued the following:

• Parity in bail: Other co-accused in the same case, convicted on similar charges, had been granted suspension of their sentences.
• Principle of equal treatment: The refusal to suspend his sentence while granting the same relief to others was arbitrary and unjust.
• Pending appeal: His appeal was still under consideration in the High Court, and suspending the sentence would not cause any harm to the judicial process.
• No additional criminal record: He had no other criminal cases pending against him, and he was willing to comply with all bail conditions.

Arguments Presented by the Respondent

The State of Madhya Pradesh opposed the appeal, presenting the following points:

• The conviction had been made based on strong evidence, and sentence suspension should not be granted lightly.
• The High Court had already considered his plea and found no grounds for suspension.
• The prosecution had concerns about the appellant’s release affecting the case.

Supreme Court Judgment

The Supreme Court examined the facts and observed that the appellant’s case was similar to those of co-accused individuals who had already been granted sentence suspension. The Court ruled that denying him the same relief would violate the principle of parity.

The key ruling was:

“It is not in dispute that the sentence has been suspended in the case of Accused Nos. 2, 3, and 4, who have been convicted and sentenced along with the appellant herein.”

Thus, the Supreme Court held that the appellant was also entitled to suspension of his sentence while his appeal was pending.

Conditions Imposed by the Supreme Court

The Court allowed bail with the following conditions:

• The appellant must deposit the entire fine amount.
• He must furnish a personal bond of Rs. 50,000 along with two solvent sureties of the same amount.
• He was required to appear before the Registry of the High Court on the last working day of every month.

Legal Precedents and Significance

The judgment is significant as it reinforces the principle that similarly situated accused individuals should be treated equally in bail matters. The Supreme Court’s decision ensures that courts follow the doctrine of parity, preventing arbitrary distinctions between co-accused individuals.

Conclusion

The case of Omprakash @ Manta vs. The State of Madhya Pradesh serves as a precedent for ensuring fairness in bail proceedings. The Supreme Court’s ruling highlights that courts must maintain consistency and parity when granting bail, preventing unjust denial of relief to similarly placed accused individuals.

Petitioner Name: Omprakash @ Manta.
Respondent Name: The State of Madhya Pradesh.
Judgment By: Justice Kurian Joseph, Justice Sanjay Kishan Kaul, Justice Navin Sinha.
Place Of Incident: Madhya Pradesh.
Judgment Date: 01-10-2018.

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