Summary
| Category | Data |
|---|---|
| Case Name | CRM(M)/977/2025 of GOUTAM MAHATO Vs STATE OF WEST BENGAL |
| CNR | WBCHCA0307192025 |
| Date of Registration | 05-07-2025 |
| Decision Date | 18-08-2025 |
| Disposal Nature | ALLOWED |
| Court | Calcutta High Court |
| Judge | HON’BLE JUSTICE SUVRA GHOSH |
| Bench | Single Judge |
| Overrules / Affirms | Affirms existing principles on bail where evidence does not support the charge |
| Type of Law | Criminal Law |
| Questions of Law |
|
| Ratio Decidendi |
The High Court held that the injury report from SSKM Hospital categorically showed head injuries resulting from a fall off a moving bike, not an offence by the petitioner. Statements under Section 164 CrPC were unsupported by the injury and post-mortem records. The companion who brought the victim to hospital was neither examined nor cited in the charge-sheet. In light of these evidentiary gaps, continued detention was not required and bail was granted under Section 439 CrPC read with Section 483 BNSS 2023. |
| Logic / Jurisprudence / Authorities Relied Upon by the Court |
|
| Facts as Summarised by the Court |
The victim sustained head injuries by falling from a running bike as per the SSKM Hospital report dated 18-03-2025. The charge-sheet under Sections 109/117(2)/126(2)/3(5) BNS and added Section 103 BNS was filed without examining a key witness. Statements under Section 164 CrPC were not corroborated by the medical evidence. |
What’s New / What Lawyers Should Note
- Injury reports indicating an accident can undermine Section 164 CrPC statements to secure bail.
- Failure to examine or cite key witnesses in the charge-sheet strengthens bail petitions.
- Courts may grant bail under Section 483 BNSS 2023 when medical evidence contradicts criminal allegations.
Summary of Legal Reasoning
- The Court reviewed the SSKM Hospital injury report: head injuries from a bike-fall, classified as a road traffic accident.
- Noted that Rohit Somaddar, who brought the victim to hospital, was neither examined by the I.O. nor listed in the charge-sheet.
- Found that statements recorded under Section 164 CrPC lacked support from the injury report and the post-mortem.
- Concluded that these evidentiary inconsistencies meant further detention of the petitioner was unnecessary.
- Exercised discretion under Section 439 CrPC read with Section 483 BNSS 2023 to grant bail.
Arguments by the Parties
Petitioner
- The injury report showed an accident, not an offence by the petitioner.
- The key witness (Rohit Somaddar) was neither examined nor cited in the charge-sheet.
- Continued detention would be an abuse of process given the evidentiary gaps.
State
- Opposed the prayer for bail without presenting counter-evidence.
Factual Background
Goutam Mahato was arrested in connection with Murutia PS Case No. 57/2025 under Sections 109, 117(2), 126(2), 3(5) BNS and added Section 103 BNS. The victim sustained head injuries from falling off a moving bike, per the SSKM Hospital report dated 18-03-2025. The victim’s companion, Rohit Somaddar, was not examined or cited. A charge-sheet was filed, and the petitioner remained in custody for about 150 days before applying for bail.
Statutory Analysis
- Considered bail under Section 439 CrPC alongside Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023.
- Examined the consistency of statements under Section 164 CrPC with medical evidence.
- Emphasized the court’s discretion to grant bail where further detention serves no purpose.
Alert Indicators
- ✔ Precedent Followed