Should Personal Liberty Under Article 21 Prevail to Warrant Anticipatory Bail Absent Criminal Antecedents?

Affirms settled law that personal liberty is paramount; anticipatory bail warranted when applicant is falsely implicated, has no antecedents, and interim bail conditions are satisfactorily met.

 

Summary

Category Data
Case Name ABA/160/2025 of JASVINDER SINGH Vs STATE OF UTTARAKHAND
CNR UKHC010016902025
Decision Date 18-08-2025
Disposal Nature ALLOWED
Judgment Author Hon’ble Mr. Justice Alok Kumar Verma
Court High Court of Uttarakhand
Bench Single-judge bench
Ratio Decidendi
  • The Court emphasised that personal liberty under Article 21 is a fundamental right that must be curtailed only when strictly necessary, based on the peculiar facts and circumstances of each case.
  • Observing that the applicant had no criminal antecedents, was falsely implicated, and complied with interim bail, the Court found no imperative to deny anticipatory bail.
  • It refrained from commenting on the merits of the underlying allegations but applied the settled principle that bail should not be denied merely because allegations involve multiple charges, absent factors like likelihood to abscond or tamper with evidence.
  • Accordingly, the Court made the interim bail absolute, prescribing a bond of Rs. 30,000 with two sureties and standard conditions to safeguard investigation and trial proceedings.
Facts as Summarised by the Court FIR dated 29.01.2024 alleged that co-accused Manjeet Singh dismantled the informant’s truck (Reg. UA005-3266) and sold its parts as scrap, and misappropriated another vehicle (Reg. UK006-CB0946) with the applicant’s connivance under Sections 420, 467, 468, 471, 120B, 504, 506 IPC.
Citations
  • [2025] UHC 7248 (Uttarakhand)
  • Anticipatory Bail Application No. 160 of 2025
  • CNR UKHC010016902025

Summary of Legal Reasoning

  • The Court invoked Article 21 of the Constitution, holding that personal liberty is a precious fundamental right and may be curtailed only when absolutely imperative under the case’s peculiar facts and circumstances.
  • It noted the absence of criminal antecedents, the applicant’s permanent residence in District Rampur (minimising flight risk), and the fact that he had complied with interim bail conditions granted on 17.02.2025.
  • Without adjudicating the substantive merits, the Court applied settled bail jurisprudence to grant anticipatory bail, emphasising that multiple charges alone do not warrant denial where there is no evidence of tampering or abscondence.
  • Consequently, the interim bail order was made absolute, subject to a personal bond of Rs. 30,000 and two sureties of like amount, along with conditions to cooperate in investigation, attend trial, avoid influencing witnesses, and not leave the country without permission.

Arguments by the Parties

Petitioner (Applicant):

  • Falsely implicated; no involvement in the alleged offence.
  • Did not receive any amount from the sale or misappropriation.
  • Co-accused Manjeet Singh granted regular bail; applicant has no criminal antecedents.
  • Permanent resident of District Rampur, Uttar Pradesh—no risk of absconding.
  • Interim bail granted on 17.02.2025 was duly complied with and not misused.

Factual Background

In Case Crime No. 24 of 2024, an FIR dated 29.01.2024 at Police Station Transit Camp, Udham Singh Nagar charged co-accused Manjeet Singh with dismantling an informant’s truck (Reg. UA005-3266) and selling its parts, and misappropriating a canter (Reg. UK006-CB0946) with the applicant’s connivance under Sections 420, 467, 468, 471, 120B, 504, and 506 IPC. The applicant sought anticipatory bail; interim bail was granted on 17.02.2025. The State and informant opposed the application before the High Court of Uttarakhand.

Citations

  • [2025] UHC 7248 (Uttarakhand)
  • Anticipatory Bail Application No. 160 of 2025
  • CNR UKHC010016902025

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