A special court in Delhi has refused bail for a second time to Manoranjan D and Sagar Sharma in the 2023 Parliament security breach case, holding that the UAPA accusations against them are prima facie true.
New Delhi: A special court in Delhi on November 12, 2026 dismissed the bail applications of Manoranjan D and Sagar Sharma, the two men accused of jumping into the Lok Sabha chamber and releasing coloured smoke on December 13, 2023, holding that the statutory bar on bail under Section 43D(5) of the Unlawful Activities (Prevention) Act applies [State v. Manoranjan D and Others].
Judge Kiran Bansal of the Special Exclusive Court (NIA Act, UAPA) passed the order. This is the second time the trial court has rejected their bail pleas.
The prosecution case
According to the prosecution, Manoranjan D and Sagar Sharma jumped from the public gallery into the Lok Sabha chamber during proceedings and released smoke canisters hidden in their shoes, while co-accused Neelam Ranoliya and Amol Shinde released canisters and raised slogans outside the building. The Delhi Police Special Cell alleges a larger conspiracy to disrupt Parliament and has charged the accused under the UAPA and other penal provisions.
What the Court said
The Court found reasonable grounds to believe that the accusations were prima facie true. Referring to witness statements under Sections 161 and 164 of the CrPC, it said:
“Statement of witnesses U/Sec.161 Cr.PC and 164 Cr.PC also reveals that the accused persons had organised meetings where the complete planning to commit the alleged terrorist act was discussed. The accused persons had thus, planned to create terror like situation and disrupt the proceedings of the Parliament on the specific date which would coincide with the 2001 Parliament Attack Anniversary.”
The Court noted that the incident caused panic among Members of Parliament and others present, that the accused were aware of a threat by Khalistani separatist Gurpatwant Singh Pannun to target Parliament, and that images of the incident were telecast on news channels immediately afterwards.
It also rejected the plea of parity with co-accused Neelam Ranoliya and Mahesh Kumawat, who were granted bail by the Delhi High Court in July 2025. Special Public Prosecutor Akhand Pratap Singh appeared for the State.
The allegations against the accused are yet to be tested at trial. The finding of a prima facie case is made only for the purpose of bail, the Court has not ruled on guilt, and the accused are entitled to the presumption of innocence.
Why the order matters
Under Section 43D(5) of the UAPA, bail must be refused if the court finds reasonable grounds to believe the accusation is prima facie true, a far stricter test than in ordinary criminal cases. The order shows that test being applied to the two men who entered the chamber, as distinct from co-accused who stayed outside and have since secured bail from the High Court.
Whether a smoke-canister protest inside Parliament amounts to a “terrorist act” under the UAPA is a question that will be decided at trial. For now, the special court has found the prosecution’s material strong enough to keep the two accused in custody.
Case Title: State v. Manoranjan D and Others (2023 Parliament Security Breach Case)
Court: Special Exclusive Court (NIA Act, UAPA), Delhi; Judge Kiran Bansal
Date of Order: November 12, 2026
For the State: Special Public Prosecutor Akhand Pratap Singh