The court clarified that bail under Section 14A(2) of the SC/ST Act may be granted when the injuries to the complainant are simple in nature and the accused have been in custody for a substantial period, particularly where the charge sheet has already been filed and no serious antecedents are present. The ruling upholds existing precedent and sets a binding authority for subordinate courts in Rajasthan, defining practical factors to be considered in bail applications under the Act.
Summary
| Category | Data |
|---|---|
| Case Name | CRLAS/1875/2025 of ANIL SON OF ATAR SINGH Vs STATE OF RAJASTHAN |
| CNR | RJHC020591262025 |
| Date of Registration | 11-07-2025 |
| Decision Date | 30-10-2025 |
| Disposal Nature | ALLOWED |
| Judgment Author | PRAMIL KUMAR MATHUR |
| Court | High Court Of Rajasthan |
| Bench | Single Bench (S.B. Criminal Appeal, Jaipur Bench) |
| Precedent Value | Binding on subordinate courts within Rajasthan |
| Overrules / Affirms | Affirms existing bail jurisprudence under the SC/ST Act |
| Type of Law | Criminal Law; Protective Legislation (SC/ST (Prevention of Atrocities) Act, 1989) |
| Questions of Law | Whether bail should be granted under Section 14A(2) of SC/ST Act in cases of simple injury and prolonged custody after filing of charge sheet. |
| Ratio Decidendi | The grant of bail under Section 14A(2) of the SC/ST Act must consider the nature of injuries (simple or grievous), the period of custody undergone by the accused, the stage of investigation (notably, whether the charge sheet has been filed), and the absence or presence of significant criminal antecedents. When injuries are simple, the accused have been in custody for a substantial period (as specified for each accused), and the charge sheet has been filed, bail may be just and proper, particularly in the absence of significant criminal antecedents. The detailed merits or demerits of the prosecution case are not to be commented upon at the stage of bail. |
| Logic / Jurisprudence / Authorities Relied Upon by the Court | The court referenced principles of fairness in prolonged custody, the non-serious nature of simple injuries, and the stage of charge sheet filing as bases for bail. |
| Facts as Summarised by the Court | The accused were charged under Sections 109(1) and 3(5) of BNS, 2023 per FIR No. 103/2025 at Police Station Kherli Mode, Bharatpur, for allegedly causing injuries to the victim by firearm; however, medical reports concluded that the injuries were simple. All appellants had been in judicial custody since May/June 2025, and the charge sheet had been filed. One appellant had a single prior criminal antecedent. The Special Judge had rejected their bail applications, leading to this appeal under Section 14A(2) SC/ST Act. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts in Rajasthan |
| Persuasive For | Other High Courts and the Supreme Court, especially regarding bail under SC/ST Act |
| Follows | General bail jurisprudence relating to Section 14A(2) of the SC/ST Act |
What’s New / What Lawyers Should Note
- Reaffirms that the nature of injuries (simple versus grievous) is a significant factor in bail considerations under the SC/ST Act.
- Highlights the importance of considering the duration of custody and the fact that the charge sheet has been filed.
- Clarifies that bail may be appropriate even when the accused is charged under stringent provisions of the SC/ST Act if the above factors are present.
- No specific merits of the case are to be determined at the bail stage; the order is confined to the question of bail only.
Summary of Legal Reasoning
- The court examined the facts alleged and the medical report, which showed only simple injuries to the complainant.
- It was noted that the accused had been in custody for a significant duration: Gautam Singh since 27.6.2025, Anil since 31.5.2025, and Rachit since 31.5.2025.
- The presence of only a single criminal antecedent for one appellant and the fact that the charge sheet had already been filed were given due consideration.
- The court determined that, in such circumstances, and without reflecting on the merits of the case, the requirements of justice warranted the grant of bail.
- The special judge’s earlier denial of bail was set aside, and directions for bail were issued accordingly.
Arguments by the Parties
Petitioner
- The appellants have been falsely implicated.
- The allegation pertains to firearm-caused injuries, but the medical report confirms only simple injuries.
- Gautam Singh has been in custody since 27.6.2025; Anil and Rachit since 31.5.2025.
- Rachit has only one prior criminal antecedent.
- Charge sheet has been filed.
- Bail should therefore be granted.
Respondent (State/Public Prosecutor)
- Vehement opposition to the grant of bail.
Complainant
- No appearance despite service; no submissions recorded.
Factual Background
The appellants were accused in FIR No. 103/2025, registered at Police Station Kherli Mode, Bharatpur, for offences under Sections 109(1) and 3(5) of the Bharatiya Nyaya Sanhita, 2023. The allegations involved causing injuries to the complainant with a firearm. Medical examination of the complainant revealed only simple injuries. The accused were remanded to judicial custody in May/June 2025. Bail applications were originally rejected by the Special Judge, SC/ST (Prevention of Atrocities) Bharatpur, prompting these criminal appeals under Section 14A(2) of the SC/ST Act.
Statutory Analysis
- Section 14A(2) of the SC/ST (Prevention of Atrocities) Act, 1989 was invoked, empowering the High Court to hear appeals against orders denying bail under the Act.
- Sections 109(1) and 3(5) of Bharatiya Nyaya Sanhita, 2023 were the substantive provisions under which the accused were charged.
- The judgment confined itself to the bail parameters under Section 14A(2), primarily focusing on custody duration, nature of injury, and charge sheet status.
Dissenting / Concurring Opinion Summary
No dissenting or concurring opinions are recorded in the judgment.
Procedural Innovations
No procedural innovations or departures from standard bail procedure are recorded in the judgment.
Alert Indicators
- ✔ Precedent Followed – The decision affirms and clarifies established bail jurisprudence under the SC/ST Act regarding consideration of the nature of injuries and duration of custody.