Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2025 Supreme(SC) 983

SUPREME COURT OF INDIA
Sandeep Mehta, Joymalya Bagchi, JJ.
Vikrant Chaudhary – Petitioner
Versus
State Of U.P. & Anr. – Respondents
Petition(s) for Special Leave to Appeal (Crl.) No(s).8764/2025 With SLP(Crl) No. 8765/2025 (II)
Decided On : 23-06-2025

Advocates Appeared:
For the Petitioner: Mr. Jugul Kishor Gupta, AOR, Mr. Raj Narayan Singh, Adv., Mr. Ravindra Kumar Sharma, Adv.
For the Respondent: Dr. Vijendra Singh, AOR, Mr. Vikas Bansal, Adv., Ms. Ashwina Lakra, Adv., Mr. Nagendra Singh, Adv., Mr. Surjeet Singh, Adv., Mr. Naman Raj Singh, Adv., M/s. Y Maheswari & Co., AOR

The Supreme Court upheld the High Court's bail order, affirming that the accused's lack of presence in the FIR and witness statements does not constitute error warranting intervention.

Headnote:(A) Bhartiya Nyaya Sanhita, 2023 - Sections 103(1) and 61(2) - Bail application - The High Court granted bail to accused who were not named in the FIR nor in eyewitness statements, relying on confessional statements - The Supreme Court found no error in the High Court's order. (Paras 2-4)

Facts of the case:
The petitioner, a complainant, assailed the bail order for the accused in connection with case Crime No. 23/25 under the above-mentioned sections.

Findings of Court:
The Court held that there was no error or infirmity in the bail grant by the High Court.

Issues: The main question was whether the High Court erred in granting bail to the accused not named in the FIR or eyewitness statements.

Ratio Decidendi: The Supreme Court ruled that the absence of the accused's names in the FIR or in eyewitness statements, coupled with reliance on confessions, did not warrant a reversal of the bail granted by the High Court.

Result: Special leave petitions dismissed.

Judgement Key Points

Certainly. Based on the provided legal document, here are the key points:

The Supreme Court of India upheld the High Court's order granting bail to the accused in a criminal case, affirming that the absence of the accused's name in the FIR and witness statements, along with reliance on confessional statements, does not constitute an error warranting intervention [judgement_subject][judgement_act_referred] (!) .
The petitioner, who is the complainant, challenged the bail order, but the Court found no error or infirmity in the High Court's decision to grant bail to the accused, as the order was based on the facts and law applicable to the case (!) (!) (!) (!) .
The Court emphasized that the accused's non-inclusion in the FIR and eyewitness statements, when bail is granted based on confessional statements, does not automatically imply an error, and such decisions are within the judicial discretion of the High Court (!) (!) .
The special leave petitions filed by the complainant were dismissed as they lacked merit, and all pending applications were disposed of accordingly (!) (!) .

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Table of Content
1. complaint details and absence of names in fir. (Para 1 , 2 , 3)
2. no error in granting bail. (Para 4)
3. dismissal of special leave petitions. (Para 5 , 6)

ORDER :

1. We have heard and considered the submissions advanced by learned counsel for the petitioner-complainant and have gone through the impugned order and the material placed on record.

2. The petitioner is the complainant of the case. He is before us by way of this special leave petition assailing the order dated 4th April, 2025 passed by the High Court of Allahabad granting bail to the accused Sandeep @ Tony (respondent No.2 in SLP(Crl.) No.8764 of 2025) and the accused Deepak (respondent No.2 in SLP(Crl.) No.8765 of 2025) in connection with case Crime No. 23/25 for the offences punishable under Sections 103 (1) and 61(2) of the Bhartiya Nyaya Sanhita, 2023.

3. It is not in dispute that respondent No.2 Sandeep @ Tony and Deepak in SLP(Crl.) No.8764 of 2025 and SLP(Crl.) No.8765 of 2025 respectively, were neither named in the FIR nor in the statements of the eye witnesses recorded during the course of the investigation. The respondents Sandeep @ Tony and Deepak have been arraigned in the case on the basis of the confessional statements of the accused.

4. In this view of the matter, we are of the firm view that there is no error or infirmity in the orders passed by the High Court granting bail to the respondent Nos.2- Sandeep @ Tony and Deepak.

5. The special leave petitions, being devoid of merit, are dismissed.

6. Pending application(s), if any, shall stand disposed of.

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Judicial Analysis

2025 Supreme(SC) 983

SUPREME COURT OF INDIASandeep Mehta, Joymalya Bagchi, JJ.Vikrant Chaudhary – PetitionerVersusState Of U.P. & Anr. – RespondentsPetition(s) for Special Leave to Appeal (Crl.) No(s).8764/2025 With SLP(Crl) No. 8765/2025 (II)Decided On : 23-06-2025

The Supreme Court upheld the High Court's bail order, affirming that the accused's lack of presence in the FIR and witness statements does not constitute error warranting intervention.

Judicial Analysis

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SUPREME COURT OF INDIA
Sandeep Mehta, Joymalya Bagchi, JJ.
Vikrant Chaudhary – Petitioner
Versus
State Of U.P. & Anr. – Respondents
Petition(s) for Special Leave to Appeal (Crl.) No(s).8764/2025 With SLP(Crl) No. 8765/2025 (II)
Decided On : 23-06-2025