Supreme Court Cancels Bail in Puran Mal vs State of Haryana Murder Case

The Supreme Court of India, in its judgment dated March 10, 2022, ruled on the case of Puran Mal vs State of Haryana & Anr., overturning the bail granted to an accused in a murder case. The accused, Mahesh Kumar, was granted bail by the Punjab and Haryana High Court despite two previous rejections by the Trial Court. The complainant, Puran Mal, challenged the High Court’s decision before the Supreme Court, arguing that bail had been granted without considering key evidence and the severity of the crime.

Background of the Case

The case involved the murder of the complainant’s brother, who sustained fatal injuries and died on the night of June 16-17, 2020. The prosecution argued that Mahesh Kumar had long-standing enmity with the deceased. Earlier that evening, the two had a scuffle, and the deceased had lodged a complaint against Mahesh Kumar. Later, while receiving treatment at a hospital, the deceased was allegedly attacked again, leading to his death.

The Trial Court rejected Mahesh Kumar’s bail applications twice, citing the gravity of the offense. However, the Punjab and Haryana High Court subsequently granted him bail, prompting the complainant to approach the Supreme Court.

Petitioner’s Arguments (Puran Mal)

The complainant, represented by Senior Advocate R. Basant, argued:

There was a history of long-standing rivalry between the accused and the deceased.
The deceased had lodged a written complaint at the police station on the evening of June 16, 2020.
The accused’s son was later called to the hospital, where he allegedly stabbed the deceased, leading to his death.
The High Court granted bail without giving proper reasons and without considering the Trial Court’s previous orders rejecting bail.
After being released on bail, Mahesh Kumar had allegedly threatened the deceased’s family members.
Serious charges were framed against the accused, including Section 302 read with Section 120B of IPC.

Respondent’s Arguments (Mahesh Kumar)

The accused, represented by Advocate Shishir Mathur, countered:

The High Court granted bail after considering discrepancies in the FIR and statements of the complainant.
CCTV footage was submitted to the High Court, which allegedly did not directly implicate the accused.
The accused had already been in custody since July 18, 2020, and the trial was expected to take time.

Supreme Court’s Observations

The Supreme Court, comprising Justices Vineet Saran and Aniruddha Bose, examined the case and made the following observations:

On the High Court’s Decision

The Supreme Court noted that the High Court’s order granting bail lacked substantive reasoning. The only justification provided was:

“As per the FIR, the petitioner had allegedly caught hold of the left hand of the deceased and Manish and Piyush @ Passu had inflicted knife blows upon the deceased, whereas the complainant got his supplementary statement recorded by improving his version…”

The Supreme Court held that this reasoning was insufficient, especially given that the Trial Court had rejected bail twice.

On the Nature of the Offense

The Court emphasized that murder is a serious offense and that granting bail requires a detailed examination of facts and evidence.

“The nature of offense in the present case is very grave. The fact that the son of the respondent no. 2 had stabbed the deceased in the presence of the respondent no. 2 is prima facie clear from the materials available before this Court and the CCTV footage which was filed before the High Court.”

On Judicial Precedents

The Court cited several previous rulings that emphasized the need for cogent reasons when granting bail in serious cases:

Niranjan Singh vs. Prabhakar Rajaram Kharote (1980) 2 SCC 559 – Courts should be satisfied of a prima facie case before granting bail.
Ram Govind Upadhyay vs. Sudarshan Singh (2002) 3 SCC 598 – High Courts must provide substantial reasons when reversing a lower court’s decision on bail.
Brijmani Devi vs. Pappu Kumar (2021 SCC Online SC 1280) – Orders granting bail in murder cases must be well-reasoned.
State of U.P. vs. Amarmani Tripathi (2005) 8 SCC 21 – The accused’s post-release conduct can be considered when deciding on bail cancellation.

Final Verdict

The Supreme Court ruled:

“In the facts of the present case, we have taken into consideration the seriousness of the offense as well as the conduct of the respondent no. 2. We also find that the respondent no. 2 in a serious case like this remained in prison only for about four months before bail was granted. There are allegations that the family of the deceased had been threatened on behalf of the respondent no. 2.”

The Court set aside the Punjab and Haryana High Court’s order granting bail and ordered the accused to be taken back into custody.

Implications of the Judgment

This ruling sets a precedent for future bail cases, particularly in murder trials:

High Courts must provide detailed reasoning when granting bail, especially if the Trial Court has previously rejected bail.
The gravity of the offense should be a crucial factor in bail decisions.
Court must consider post-release conduct when deciding on bail cancellations.
CCTV footage and phone records should be properly examined before making a bail decision.

Conclusion

The Supreme Court’s ruling in Puran Mal vs. State of Haryana reaffirms that bail in serious cases like murder must be granted with due diligence. The decision ensures that judicial discretion is exercised cautiously, and bail orders are not passed arbitrarily. This judgment strengthens the principles of justice by ensuring that procedural errors do not lead to unjustified bail approvals.

Petitioner Name: Puran Mal.
Respondent Name: State of Haryana & Anr..
Judgment By: Justice Vineet Saran, Justice Aniruddha Bose.
Place Of Incident: Haryana.
Judgment Date: 10-03-2022.

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