1. Special Leave Petitions challenging High Court orders granting regular bail to accused persons not named in the FIR. (Para 2 )
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2025 Supreme(SC) 987
SUPREME COURT OF INDIA
Sandeep Mehta, Joymalya Bagchi, JJ.
Meenu Rai - Petitioner
Versus
State Of Uttar Pradesh & Anr. - Respondents
Special Leave Petition (Criminal) Diary No(s). 32449/2025 With Diary No(s). 32453/2025 (II)
Decided On : 23-06-2025
Advocates Appeared:
For the Petitioner: Mr. Sri Narayan Shukla, Adv., Mr. Kamal Kant Tripathi, Adv., Mr. Sanjay Mani Tripathi, Adv., Mr. Gaurav Singh, Adv., Ms. Anu Gupta, AOR
For the Petitioner: Mr. Sri Narayan Shukla, Adv., Mr. Kamal Kant Tripathi, Adv., Mr. Sanjay Mani Tripathi, Adv., Mr. Gaurav Singh, Adv., Ms. Anu Gupta, AOR
Bail can be granted when allegations against the accused are not explicitly detailed in the FIR, and the court finds no error in the decision of the High Court.
Headnote:(A) Criminal Procedure Code, 1973 - Grant of regular bail - Complainant assails High Court's bail order for private respondents who were not named in the FIR - Allegations of causing fatal blow not attributed to the accused - No error found in High Court's decision to grant bail. (Para 3)
Facts of the case:
The complainant's Special Leave Petitions challenge the High Court's grant of bail to private respondents, who were not named in the FIR and against whom specific allegations were not made.
Findings of Court:
The Court found that the High Court did not err in granting bail to the respondents in light of the allegations.
Issues: Main issue addressed was whether the High Court erred in granting bail to private respondents not named in FIR.
Ratio Decidendi: The court concluded that since the allegations did not specifically implicate the respondents, the bail order was justified, emphasizing the absence of merit in the complainant’s petitions.
Result: Special Leave Petitions rejected.
Legal Category Hierarchy
Table of Contents
2. Complainant assails the High Court's decision to grant regular bail to the private respondents. (Para 2 )
3. Accused were not named in the FIR and no specific allegation of causing the fatal blow was attributed to them. (Para 2 , 3 )
4. Absence of names in the FIR and lack of specific allegations regarding the fatal blow justify the grant of regular bail. (Para 2 , 3 )
5. Special Leave Petitions rejected; High Court's bail orders upheld. (Para 3 )
6. Does the absence of an accused's name in the FIR and lack of specific allegations regarding the fatal blow support the grant of bail?
Yes, where the accused are not named in the FIR and no specific allegation of causing the fatal blow is attributed to them, the grant of regular bail by the High Court is considered appropriate. (Para 2 , 3 )
ORDER :
1. Permission to file Special Leave Petitions is granted.
2. The complainant is before us by way of these Special Leave Petitions for assailing the orders whereby, the private respondent No(s).2 in both these Special Leave Petitions, namely, Deepansh Rai and Ankit Rai, have been granted regular bail by the High Court. On perusal of the impugned orders and the material placed on record, we find that even though both these respondents were known to the petitioner prior to the incident, they were not named in the FIR.
3. The specific allegation of causing fatal blow is not attributed to either of the private respondents-accused. In this view of the matter, we are of the opinion that the High Court did not commit any error whatsoever in granting bail to the accused. The Special Leave Petitions, being devoid of merit, are hereby rejected.
4. The observations made hereinabove are limited for the disposal of the present Special Leave Petitions and shall not prejudice the proceedings before the trial court.
5. Pending application(s), if any, shall stand disposed of.
