Sangram Singh @ Sonu, S/o Raghuraj Singh v. State Of Rajasthan, Through Pp
2025-11-25
SAMEER JAIN
body2025
DigiLaw.ai
ORDER : SAMEER JAIN, J. 1. Before proceeding to consider the present applications seeking grant of bail to the accused-applicants, this Court considers it appropriate and necessary to delineate, at the outset, the factual matrix of the alleged incident, as has been placed on record and articulated by the learned counsel appearing on behalf of the accused-applicants across all the connected bail applications. Accordingly, the foundational facts, forming the substratum of the present case are summarised and set out hereinbelow: 1.1 That an FIR bearing No. 0100/2025 has been lodged on 31.03.2025 by the complainant, Shri Naresh Chaudhary, at Police Station Talera, District Bundi, alleging commission of offences punishable under Sections 103 (1) and 189(2) of the Bharatiya Nyaya Sanhita, 2023 against the accused-applicants. The said FIR sets in motion the criminal law with respect to the incident forming the subject matter of the present bail applications. 1.2 That as per the recitals contained in the FIR, it is alleged that the victim-Lokendra, had been brutally assaulted by a group of individuals, the accused-applicants herein, at a location in the vicinity of Talera. It is further alleged that the victim sustained grievous injuries during the said assault and was profusely bleeding from his nose and ears. Despite being immediately taken for medical treatment, the victim is stated to have succumbed to his injuries during the course of treatment at a hospital in Kota. 1.3 That the FIR further narrates that at another point during the sequence of events, an altercation ensued between the parties wherein accused-applicants Bana and Prahalad are specifically alleged to have kicked and punched the victim, and thereafter inflicted a blow on the victim’s head with a knife, causing severe head injury. 1.4 That as per the post-mortem examination report placed on record, the cause of death has been opined to be “head injury – sufficient to cause death in the ordinary course of nature,” thereby prima facie corroborating the allegation of fatal head trauma sustained by the deceased. In SBCRLMBA No. 9562/2025 2. Learned counsel appearing on behalf of the applicants had submitted that the applicants are young individuals and are the sole earning members of their respective families, upon whom their dependents rely for subsistence.
In SBCRLMBA No. 9562/2025 2. Learned counsel appearing on behalf of the applicants had submitted that the applicants are young individuals and are the sole earning members of their respective families, upon whom their dependents rely for subsistence. It was urged that the continued incarceration of such individuals would cause irreparable hardship to their families and would not serve any fruitful purpose in the facts of the present case. 3. It was further contended that the applicants do not have any criminal antecedents and have maintained a clean record prior to the present incident and that their implication appears to be more a consequence of suspicion and group rivalry than of their actual involvement in the alleged offence. 4. Learned counsel had also pointed out that the complainant, Shri Naresh Chaudhary, was admittedly not an eye-witness to the occurrence in question. Instead, one Dharamraj was present with the deceased-victim at the time of the incident and is the only competent person who could speak to the actual sequence of events. It was further urged that the allegations contained in the FIR are omnibus and general in nature, implicating a group of persons collectively without attributing any specific overt act to the present applicants. Learned counsel submitted that this lack of specific role assignment disentitles the prosecution to oppose bail merely on the basis of collective allegations, particularly when no material has been brought forth to demonstrate that the applicants individually participated in the assault leading to the death of the victim. 5. Per contra, learned Public Prosecutor had vehemently opposed the instant bail application. 6.
5. Per contra, learned Public Prosecutor had vehemently opposed the instant bail application. 6. Having heard the submissions made by learned counsel for the parties and upon perusal of the material available on record, this Court is not inclined to grant the relief of bail to the accused- applicants, for the reason that the investigation material, including the site inspection report and statements recorded under Section 180 BNSS unequivocally indicates the presence of the applicants at the place of occurrence at the relevant time; that their presence at the scene stands prima facie established and is further corroborated by CCTV footage recovered during investigation, which captures the applicants in the immediate proximity of the victim shortly prior to and during the commission of the alleged assault; that the nature of the offence alleged is grave and heinous, involving a brutal assault resulting in the death of the victim; that the medical report opining the cause of death as a fatal head injury sufficient to cause death in the ordinary course of nature, coupled with the collective conduct attributed to the applicants, demonstrates the seriousness of the accusations. 7. At the bail stage, the Court is required to consider the gravity of the offence, the manner of its commission, and the likelihood of the accused influencing witnesses or tampering with material evidence. The allegations herein reflect a coordinated attack by a group of persons, and the role of each participant including the present applicants and facilitating the occurrence cannot be lightly overlooked. Therefore, in view of the ocular and electronic evidence collected thus far, the active presence and alleged participation of the applicants cannot be ruled out. Thus, considering the gravity of the accusation, the nature of the evidence collected, and the potential impact on the administration of justice, this Court is of the considered view that the applicants do not deserve indulgence at this stage. Consequently, the application for grant of bail stands dismissed. In CRLMBA No. 10260/2025 8. Learned counsel appearing for the applicant submitted that the applicant has been falsely implicated in the present case and that the prosecution story, as set out in the FIR, does not attribute any role whatsoever to the applicant.
Consequently, the application for grant of bail stands dismissed. In CRLMBA No. 10260/2025 8. Learned counsel appearing for the applicant submitted that the applicant has been falsely implicated in the present case and that the prosecution story, as set out in the FIR, does not attribute any role whatsoever to the applicant. It was submitted that the FIR does not contain even a bare reference to the name of the applicant, nor does it narrate any specific overt act, presence, or participation of the applicant in the alleged incident. Learned counsel contended that the applicant’s subsequent implication is a result of afterthought, general suspicion, and alleged group rivalry rather than any material forming part of the initial version of the complainant. 9. It was contended that the applicant is the sole breadwinner for his family, and his prolonged incarceration is causing grave hardship to his dependents. It was next argued that the investigation is substantially complete, and that continued detention of the applicant would serve no useful purpose, especially when the trial is likely to take considerable time. 10. Per contra, learned Public Prosecutor had vehemently opposed the instant bail application. 11. Having heard the submissions made by learned counsel for the parties and upon perusal of the material available on record, this Court is not inclined to grant the relief of bail to the accused- applicants, for the reason that the investigation material, including CCTV recording unequivocally indicates the presence of the applicant at the place of occurrence at the relevant time; that the nature of the offence alleged is grave and heinous, involving a brutal assault resulting in the death of the victim; that there are as many as seven criminal antecedents registered against the accused-applicant (as also noted in the impugned bail dismissal order dated 15.07.2025). 12. Therefore, in view of the aforementioned, considering the gravity of the accusation, the nature of the evidence collected, and the potential impact of enlarging the accused-applicant on bail especially when he has seven criminal antecedents discredited to him, this Court is of the considered view that the applicants do not deserve indulgence at this stage. Consequently, the application for grant of bail stands dismissed. In CRLMBA No. 10881/2025 13. Learned counsel appearing on behalf of the applicant had submitted that the applicant is a young man, who is also the sole breadwinner for his family.
Consequently, the application for grant of bail stands dismissed. In CRLMBA No. 10881/2025 13. Learned counsel appearing on behalf of the applicant had submitted that the applicant is a young man, who is also the sole breadwinner for his family. It was further submitted that the applicants’ prolonged incarceration is causing grave hardship to his dependents. It was next argued that the investigation is substantially complete, and that continued detention of the applicant would serve no useful purpose, especially when the trial is likely to take considerable time. 14. Per contra, learned Public Prosecutor had vehemently opposed the instant bail application. 15. Having heard the submissions made insofar, and taking note of the fact that the CCTV footage, as recovered by the police authorities during the investigation, has reflected the presence of the accused-applicant at the crime scene; that the applicant has three criminal antecedents registered against him (as also noted in the impugned bail rejection order dated 25.04.2025); that the nature of injuries inflicted and allegations leveled are heinous and serious, this Court is not inclined to enlarge the accused-applicant on bail. 16. Accordingly, the instant bail application is dismissed. In CRLMBA No. 14269/2025 17. Learned counsel appearing on behalf of the applicant had submitted that the applicant is the sole earning member of his family, upon whom his dependents rely for subsistence. It was urged that the continued incarceration of such individuals would cause irreparable hardship to the family and would not serve any fruitful purpose in the facts of the present case. 18. It was further contended that the applicant has only one criminal antecedent registered against himself, and that his implication appears to be more a consequence of suspicion and group rivalry than of his actual involvement in the alleged offence. 19. Per contra, learned Public Prosecutor had vehemently opposed the instant bail application. 20. Having heard the submissions made by the learned counsel representing the parties, upon a perusal of the material available on record, and taking note of the fact that there is a criminal antecedent registered against the accused-applicant; that there have been direct allegations in the contents of FIR against the accused-applicant; that the CCTV recording prima facie substantiates the story of prosecution; that the nature of injuries inflicted and allegations leveled are heinous in nature, this Court is not inclined to allow the instant bail application. 21.
21. Accordingly, the instant bail application is dismissed. CONCLUSION: 22. In view of the totality of material placed on record, this Court finds no justifiable ground to enlarge the accused-applicants on bail at this stage. The prima facie gravity and heinous nature of the offence, the manner of assault resulting in a fatal head injury, coupled with credible material indicating the presence and active participation of the applicants at the crime scene, weigh heavily against the grant of bail. The available CCTV footage and witness statements, though subject to proof at trial, presently constitute strong prima facie evidence that cannot be ignored at the pre-trial stage. Nevertheless, Hon’ble Supreme Court has, on numerous occasions, emphasised that in cases involving grave and serious offences particularly those resulting in loss of life the Courts must exercise greater caution while considering bail. In State of U.P. v. Amarmani Tripathi , (2005) 8 SCC 21 , the Hon’ble Supreme Court held that the nature and gravity of the offence, the role of the accused, and the likelihood of the accused tampering with evidence are paramount considerations. Likewise, in Kalyan Chandra Sarkar v. Rajesh Ranjan @ Pappu Yadav : (2004) 7 SCC 528 , Ram Govind Upadhyay vs. Sudarshan Singh and Ors. (2002) 3 SCC 598 and Puran Mal v. State of Haryana : (Arising out of Special Leave Petition (Crl.) No. 1168 of 2021) the Court reiterated that bail cannot be granted where the accusations are grave, evidence is substantial, and the likelihood of interfering with the administration of justice exists. 23. Applying the principles laid down in the above precedents to the facts of the present case, this Court is of the considered opinion that the evidence presently available particularly the CCTV footage, corroborating eye-witness accounts, and the medical opinion attributing death to a head injury caused in the ordinary course of nature militates strongly against the release of the applicants on bail. Allowing bail in such circumstances may prejudice the fair conduct of the trial and may also create a reasonable apprehension of the applicants influencing witnesses from the same locality. 24. Therefore, in light of the seriousness of the allegations, the nature of evidence collected, and a catena of judgments passed by Hon’ble Supreme Court governing the principles of bail, this Court is of a view that the present applications being devoid of merit stand dismissed. 25.
24. Therefore, in light of the seriousness of the allegations, the nature of evidence collected, and a catena of judgments passed by Hon’ble Supreme Court governing the principles of bail, this Court is of a view that the present applications being devoid of merit stand dismissed. 25. A copy of this order be separately placed in each connected file.