Can Bail Under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 Be Granted When Prima Facie Material and Gravity of the Offence Are Established?

 

Summary

Category Data
Case Name CRM(M) 1080 of 2025 (Saifuddin Goldar v. State of West Bengal)
CNR WBCHCA0323772025
Decision Date 18-08-2025
Disposal Nature Rejected
Judgment Author Hon’ble Justice Suvra Ghosh
Court Calcutta High Court
Bench Single-Judge
Type of Law Criminal Procedure (BNS Act, 2023)
Ratio Decidendi
  • The High Court held that bail under Section 483 of the BNS Act is a discretionary remedy that must be refused where:
  • Prima facie material—such as eyewitness identification, mobile‐tower location data, and hotel booking via the accused’s Aadhaar—links the petitioner to a grave offence.
  • The nature and gravity of the charge (murder under Sections 103/61(2)) warrant custodial trial to safeguard the investigation and ensure the accused’s presence.
Facts as Summarised by the Court
  • A dead body was found in a hotel parking lot booked with the petitioner’s Aadhaar.
  • FIR under Sections 103/61(2) BNS Act alleges a hired contract killing involving the petitioner and two others.
  • An eyewitness saw the petitioner fleeing; mobile‐tower records placed him at the scene.
  • The principal accused had already obtained bail.

Summary of Legal Reasoning

  1. Prima facie material: The Court noted eyewitness testimony of the petitioner fleeing the scene, mobile‐tower data locating his phone at the time of the incident, and hotel booking in his name.
  2. Nature and gravity: The alleged offence—murder punishable under Sections 103/61(2) of the BNS Act—is “serious” and impacts the course of justice if prematurely bailed.
  3. Discretion under Section 483: Applying its inherent jurisdiction, the High Court held that bail should be denied where the record discloses believable evidence of involvement and the offence’s severity justifies continued custody.
  4. Conclusion: In light of the above, bail was refused to preserve investigatory integrity and ensure trial attendance.

Arguments by the Parties

Petitioner

  • The prosecution case rests solely on circumstantial evidence without direct nexus linking him to the murder.
  • The principal accused has been granted bail, suggesting parity in treatment.

State

  • The petitioner allegedly arranged the murder by hiring the principal accused, who then engaged two others.
  • An independent witness saw him fleeing; his Aadhaar was used to book the hotel.
  • Mobile‐tower data places his phone at the crime scene at the relevant time, creating prima facie involvement.

Factual Background

In early September 2024, a body was discovered in a hotel parking lot booked with the petitioner’s Aadhaar. The FIR under Sections 103 and 61(2) of the Bharatiya Nagarik Suraksha Sanhita, 2023 accused the petitioner of hiring the principal accused for a contract killing, who then involved two others. Eyewitnesses reported seeing the petitioner and two accomplices flee immediately after the incident, and mobile‐tower records corroborated his presence at the scene. The principal accused had obtained bail, prompting the petitioner’s Section 483 application.

Statutory Analysis

  • Section 483, BNS Act, 2023: Confers the High Court with inherent power to grant or refuse bail.
  • The Court reaffirmed that this power is exercised sparingly—bail must be denied where credible material demonstrates involvement and the offence’s seriousness.

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