Supreme Court Cancels Anticipatory Bail in Madhya Pradesh Murder Case

The Supreme Court of India has delivered a crucial judgment in Prashant Singh Rajput vs. The State of Madhya Pradesh & Anr., where it set aside anticipatory bail granted by the Madhya Pradesh High Court in a murder case. The Court ruled that the High Court failed to consider the gravity of the offense and the specific allegations against the accused before granting bail. This decision highlights the necessity for judicial scrutiny in granting anticipatory bail in serious criminal cases.

Background of the Case

The case revolves around a murder that occurred in Majholi, District Jabalpur, Madhya Pradesh, where the victim, Vikas Singh, was shot dead. The prosecution alleged that the accused—Jogendra Singh and Suryabhan Singh—played active roles in the crime. According to the FIR filed on September 29, 2020, Vikas Singh was attacked due to previous enmity involving illegal sand mining disputes.

The complaint named four accused: Ujiyar Singh, his sons Chandrabhan Singh and Suryabhan Singh, and his driver Jogendra Singh. It was alleged that Ujiyar and Chandrabhan shot the victim, while Jogendra held him down, preventing him from escaping, and Suryabhan assaulted the complainant with the butt of his rifle.

Jogendra and Suryabhan sought anticipatory bail, which was granted by the Madhya Pradesh High Court. The complainant, Prashant Singh Rajput, approached the Supreme Court, arguing that the bail was granted without considering the seriousness of the allegations.

Arguments by the Petitioner (Complainant)

The complainant’s counsel, Mr. Uday Gupta, made the following arguments:

The High Court relied solely on the investigation report without considering the FIR and witness statements.
Eyewitnesses had directly implicated Jogendra Singh and Suryabhan Singh in the murder.
The trial court had noted multiple discrepancies in the investigation report, particularly in how the accused’s presence at the crime scene was dismissed.
The anticipatory bail ignored the serious nature of the offense and failed to consider that both accused had absconded during the investigation.

Arguments by the Respondents (Accused)

The accused, represented by their respective counsels, made the following counterarguments:

The police report showed that both accused were in Jabalpur, about 40 km from the crime scene.
There was a long-standing dispute between the accused and the complainant’s family over illegal sand mining, and the FIR was allegedly filed as retaliation.
The complainant’s statements had inconsistencies, such as changes in the timeline of events.
The prosecution had not provided sufficient evidence linking the accused to the crime beyond the statements of the complainant.

Supreme Court’s Judgment

The Supreme Court carefully analyzed the facts and legal principles surrounding anticipatory bail and concluded that the High Court had erred in granting relief to the accused. The key observations of the Court included:

“The FIR and witness statements provide a prima facie case against the accused, which the High Court failed to consider.”
The investigation had procedural lapses, such as reliance on mobile tower records without confirming whether the accused personally used the registered numbers.
The High Court should not have dismissed the prosecution’s claims solely based on the police report.
Given the gravity of the offense, the High Court should have applied stricter scrutiny before granting anticipatory bail.

The Supreme Court ruled that anticipatory bail granted to Jogendra Singh and Suryabhan Singh was unsustainable and must be revoked.

Legal Implications of the Judgment

This ruling reinforces several legal principles:

Anticipatory bail should not be granted in serious criminal cases unless compelling reasons exist.
Courts must consider FIR allegations and witness statements before deciding on bail applications.
Judicial scrutiny is necessary when lower courts rely solely on police investigation reports.
In cases involving absconding accused, bail should not be granted without thorough examination of the circumstances.

Conclusion

The Supreme Court’s decision in Prashant Singh Rajput vs. The State of Madhya Pradesh underscores the importance of judicial diligence in granting anticipatory bail. The ruling sends a strong message that courts must evaluate all material evidence before granting relief in serious criminal cases. By canceling the bail, the Court ensures that justice is served and the trial process remains uncompromised.

Petitioner Name: Prashant Singh Rajput.
Respondent Name: The State of Madhya Pradesh & Anr..
Judgment By: Justice Dhananjaya Y Chandrachud, Justice B.V. Nagarathna.
Place Of Incident: Jabalpur, Madhya Pradesh.
Judgment Date: 08-10-2021.

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