The Supreme Court of India held that absence of an accused’s name in inquest proceedings alone cannot justify bail if investigation materials prima facie indicate involvement, while setting aside an Allahabad High Court order granting bail in a murder case.
The Supreme Court has held that the mere absence of an accused person’s name in inquest proceedings cannot, by itself, become a ground for granting bail when other material collected during investigation prima facie points towards the accused’s involvement in the crime.
A Bench comprising Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh passed the ruling while setting aside an order of the Allahabad High Court that had granted bail to an accused in a murder case primarily on the ground that his name did not appear in the inquest proceedings.
The top court observed that in serious criminal cases, courts dealing with bail applications must carefully evaluate the overall evidence gathered during investigation instead of relying on isolated aspects of the record.
The Bench emphasised that omission of an accused’s name from an inquest report loses significance when other materials on record corroborate the prosecution’s allegations and establish a prima facie connection between the accused and the offence.
According to the Court, the Allahabad High Court failed to properly appreciate crucial materials available in the case diary, including the chargesheet, witness statements and recovery evidence.
The Supreme Court noted that the post-mortem report supported the prosecution’s version of events, while the alleged murder weapon was also recovered at the instance of the accused. Additionally, statements of witnesses recorded under Section 180 of the Bharatiya Nagarik Suraksha Sanhita, 2023, had also implicated the accused in the crime.
The Bench observed that these pieces of evidence could not be brushed aside merely because the accused’s name did not figure in the inquest proceedings.
The case arose out of a murder FIR in which Respondent No. 2 had already been named as an accused. Although his name was not mentioned during the inquest proceedings conducted after the death, the trial court refused to grant him bail after considering the gravity of allegations, medical evidence and the alleged recovery of the weapon used in the offence.
Thereafter, the accused approached the Allahabad High Court seeking bail. The High Court granted relief by observing that the omission of the accused’s name in the inquest report created doubt regarding the prosecution story.
The complainant subsequently challenged the High Court’s order before the Supreme Court by filing a Special Leave Petition.
Allowing the appeal, the Supreme Court held that the High Court committed an error by ignoring other corroborative evidence collected during investigation.
The Bench also clarified the limited scope and purpose of inquest proceedings under criminal law. It explained that an inquest is merely a preliminary exercise conducted to ascertain the apparent cause of death and surrounding circumstances. It is not meant to serve as a detailed investigation report or an exhaustive narration of the entire incident.
The Court further observed that inquest proceedings are not expected to contain the names of all accused persons or every minute detail connected with the offence.
The Bench stated that merely because the accused was not named in the inquest report, an adverse inference against the prosecution could not have been drawn when subsequent investigation produced material linking him to the crime.
Holding that the High Court had adopted an incorrect approach while granting bail, the Supreme Court set aside the order and directed Respondent No. 2 to surrender before the concerned authorities.
Case Title: Bhagat Singh v. State of Uttar Pradesh & Anr.
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