The Supreme Court observed that merely because an accused person’s name was not mentioned during inquest proceedings, bail cannot be granted if other materials on record prima facie point towards the accused’s involvement in the crime.

A Bench of Justice Sanjay Karol and Justice Nongmeikapam Kotiswar Singh set aside an Allahabad High Court order that had granted bail to an accused in a murder case on the ground that his name did not surface during the inquest proceedings.

The Court emphasised that in cases involving serious allegations, courts must exercise caution while granting bail and carefully examine the material collected during investigation. It said that omission of an accused’s name in the inquest report loses significance when there are other corroborative circumstances linking the accused to the offence.

The Bench noted that the chargesheet, the post-mortem report supporting the prosecution version, recovery of the alleged weapon at the instance of the accused, and witness statements recorded under Section 180 of the Bharatiya Nagarik Suraksha Sanhita, 2023, were all relevant circumstances that the High Court failed to adequately consider.

According to the Court, these materials prima facie implicated the accused and could not have been brushed aside solely because his name was absent in the inquest proceedings.

The matter arose from a murder case in which an FIR had already named Respondent No.2 as an accused. During the inquest proceedings, however, his name was not mentioned. Despite this omission, the Sessions Court refused to grant bail after considering the seriousness of the allegations, the medical evidence, and the alleged recovery of the murder weapon from the accused.

The accused later approached the Allahabad High Court, which granted him bail while observing that the omission of his name in the inquest proceedings created doubt over the prosecution’s case.

Challenging this order, the informant moved the Supreme Court through a Special Leave Petition.

Allowing the appeal, the Supreme Court held that the High Court committed an error by ignoring the other corroborative materials available on record.

The Court also clarified the limited scope of inquest proceedings, observing that an inquest is only a preliminary inquiry conducted to ascertain the apparent cause of death. It is not meant to provide a detailed account of the incident or identify all accused persons involved in the crime.

The Bench further held that non-mention of the accused in the inquest report, by itself, cannot become a ground to doubt the prosecution case when the accused is subsequently implicated during investigation through other evidence.

Holding that the High Court had wrongly drawn an adverse inference against the prosecution, the Supreme Court allowed the appeal and directed Respondent No.2 to surrender.

The case is titled Bhagat Singh v. State of Uttar Pradesh & Anr..