The Supreme Court set-aside the Allahabad High Court’s decision granting bail to a murder accused, ruling that the justification of gathering evidence to prove innocence lacked valid grounds and did not warrant such extraordinary indulgence from the court.
New Delhi: The Supreme Court has set-aside an Allahabad High Court order that granted bail to a murder suspect, emphasizing that further detention of the accused could harm his ability to defend himself during the trial and would violate the principles of fairness in criminal procedure.
A bench comprising Justices Vikram Nath and Sandeep Mehta deemed the High Court’s decision from May 12, 2025, erroneous and upheld an appeal by informant Irfan.
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In a second bail application from the accused, Riyasuddin, the High Court argued that his continued detention would hinder his defense strategy and prevent him from collecting evidence to demonstrate his innocence.
Riyasuddin faced charges in District Bulandshahar under Sections 147, 148, 302, 304, and 34 of the Indian Penal Code, accused of murdering the complainant’s father, Idris, and injuring his brother, Imram. The complaint alleged that Riyasuddin and his two sons, Sarfaraz and Umardin, along with a man named Afsar, pursued the complainant’s father into a mosque and shot him.
The apex court noted that the High Court had relied on a prior decision in the case of Prabhat Gangwar vs. State of UP, which indicated that a court must assess whether releasing the accused is necessary for them to prepare their defense and gather evidence to counter the prosecution.
The Gangwar case also highlighted that “setting an accused at liberty at large on this ground cannot be applied mechanically in all cases.”
Each situation must be examined based on its unique facts and circumstances, considering all relevant evidence, the accused’s conduct, and the trial process.
Justice Nath’s bench pointed out that while the High Court could grant bail to allow the accused to prepare his defense, such a decision cannot be made without careful consideration of the specifics of each case.
The Supreme Court clarified that the principles from the Prabhat Gangwar case should only be applied in exceptional circumstances and must be evaluated in light of the observations made in that judgment.
In the current case, the Supreme Court found that the High Court did not adequately assess the facts and circumstances, granting bail too broadly based on the argument that further detention would impair the accused’s defense.
The bench stated,
“Apparently, no such basis has been set out by Respondent No.2 for seeking bail as to what kind of defence strategy and the evidence that was required to be collected or what were the special facts and circumstances of the case which required this kind of indulgence. We are, therefore, not satisfied with the impugned order and are accordingly inclined to set it aside,”
The court ordered the accused to surrender within four weeks and instructed the Trial Court to complete the trial within three months.
Case Title: Irfan vs. State of Uttar Pradesh & Anr