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Allahabad High Court

SAJJAN SINGHversusSTATE OF U.P.

Decided

Holding

The court granted bail to the accused, ordering release on personal bond and sureties, without delving into the merits of the underlying charges.

Summary

The accused, Sajjan Singh, filed a bail application in a criminal case (Crime No. 161 of 2026) involving alleged theft and offences under Sections 331(4), 305(A), 317(2) and 317(4) of the IPC. The FIR was initially lodged against anonymous persons, and the accused was later identified through a police disclosure statement after being arrested in another matter. The applicant has a substantial criminal history with 27 cases, is on bail in most of them, and has been in custody since 19 June 2026, seeking release pending trial. The State opposed bail but did not contest the factual background presented by the applicant. The High Court, after considering the submissions, allowed the bail application without addressing the merits of the case, directing the applicant to furnish a personal bond and two sureties. The order referenced Supreme Court precedents in Girish Gandhi v. State of Uttar Pradesh (2024) 10 SCC 674 and Policy Strategy for Grant of Bail in Re (2024) 10 SCC 685.

Issues considered

  • Whether bail should be granted in a case involving theft and offences under Sections 331(4), 305(A), 317(2) and 317(4) of the IPC despite the accused's extensive criminal history.
  • Whether identification of the accused through a police disclosure statement suffices for bail considerations.
  • How the Supreme Court’s recent bail jurisprudence (Girish Gandhi and Policy Strategy cases) applies to the present application.

Legislation cited

Subjects

  • bail
  • criminal procedure
  • Indian Penal Code
  • disclosure statement
  • prior criminal history
  • Supreme Court bail jurisprudence
  • Allahabad High Court

Judgment

         HIGH COURT OF JUDICATURE AT ALLAHABAD
         CRIMINAL MISC. BAIL APPLICATION No. - 28727 of 2026

Sajjan Singh
                                                            .....Applicant(s)
                                   Versus

State of U.P.
                                                                .....Opposite
                                                                      Party(s)

Counsel for Applicant(s)                    :   Sandhya Chaturvedi
Counsel for Opposite Party(s)               :   G.A.

Court No. - 69
                    HON'BLE AVNISH SAXENA, J.

1. Heard Ms. Sandhya Chaturvedi, learned counsel for the accused-
applicant and learned A.G.A. for the State.

2. The present bail application has been moved by the accused-applicant
Sajan Singh to enlarge him on bail in Case Crime No. 161 of 2026, under
Sections 331(4), 305(A), 317(2), 317(4) BNS, P.S.- Ajeetmal, District-
Auraiya, during the pendency of trial.

3. It is contended by learned counsel for the accused-applicant that the
F.I.R. has been lodged against the anonymous persons on 01.06.2026 for
the incident of 18.05.2026, with the allegation that there was a theft in the
house of informant, wherein cash and jewellery has been stolen. Further
contended that the name of the accused-applicant has been figured out
when the police has arrested the accused-applicant in another case and on
the basis of disclosure statement, the accused-applicant has been
implicated in this case. Further contended that the recovery of some cash
at the instance of the accused-applicant and other accused. The applicant
has 27 cases criminal history and all the cases have been levelled by the
police against the accused-applicant pertaining to theft. He is on bail in 24
cases, but he could procure the bail orders of 21 cases, as in three cases,
the bail orders are not available and in remaining three cases, the accused-
applicant is in jail. The charge sheet is submitted. The applicant is in jail
since 19.06.2026 and hence, the applicant seeks to be released on bail.

4. Learned A.G.A. for State has opposed the prayer for bail of the
                                                                                            BAIL No. 28727 of 2026
                                                                    2


                                    applicant, but could not dispute the aforesaid facts.

                                    5. This Court has taken into consideration the rival submissions made by
                                    learned counsel for the parties and perused the record.

                                    6. Considered that the name of accused-applicant has been reflected on
                                    the basis of disclosure statement.

                                    7. Hence, without touching merit of the case, the bail application is
                                    allowed.

                                    8. The accused/applicant be released on bail in the aforesaid case on
                                    furnishing a personal bond and two sureties each in the like amount to the
                                    satisfaction of court concerned in view of observation made by the
                                    Supreme Court in its dictums of Girish Gandhi Vs. State of Uttar
                                    Pradesh [(2024) 10 SCC 674] and Policy Strategy for grant of bail in
                                    re [(2024)10SCC 685].

                                    9. The accused-applicant shall cooperate in judicial process for fair and
                                    speedy disposal.



                                                                                            (Avnish Saxena,J.)
                                    September 29, 2026
                                    Shivangi




Digitally signed by :-
SHIVANGI YADAV
High Court of Judicature at Allahabad


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