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Supreme Court of India 2021-04-20 allowed

Ramesh Bhavan Rathod vs Vishanbhai Hirabhai Makwana Makwana (Koli) & Anr

Bench: 2 — Dhananjaya Y. Chandrachud

In Brief

Six persons charged in connection with five homicidal deaths in a premeditated group assault sought bail from the Gujarat High Court. The High Court granted bail based partly on discrepancies between the FIR and a subsequent statement, and on parity with an earlier grant. The Supreme Court set aside all six bail orders, holding they suffered from clear perversity and non-application of mind. The Court emphasized that at the bail stage, the presence of the accused, their armed intent (confirmed by the accused's own cross-FIR), premeditation, and the resulting deaths were determinative. The Court reaffirmed that courts must consider the gravity of offences, evidence of involvement, and public interest in criminal justice, and must record reasons for bail decisions that are beyond formulaic assertions. Whether injuries resulted from firearms or blunt weapons was immaterial where the cross-FIR itself corroborated the accused's presence and assault intent.

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Criminal Procedure Bail Discretion Homicide Premeditation Reasoning in Judicial Orders Parity Principle Public Interest

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