Allahabad High Court
RANJEET PATELversusSTATE OF U.P.
- Decided
Holding
The court held that, given the lack of substantive evidence, the delayed FIR, and the imperative to reduce jail overcrowding, the applicant is entitled to bail.
Summary
The Allahabad High Court considered a bail application filed by Ranjeet Patel in a criminal case (Crime No. 167 of 2025) where the FIR was lodged three months after the alleged incident. The applicant claimed false implication, lack of incriminating material, and that the death was due to an antemortem head injury from a fall, not abetment of suicide. The prosecution highlighted call records linking the applicant with the co-accused and the deceased, and argued the applicant's prior criminal record. The court, noting the delay in filing the FIR, absence of substantive evidence, the need to decongest jails, and Supreme Court precedents on bail, decided to grant bail without commenting on the merits. The bail was ordered with a personal bond, two sureties, and specific conditions, and procedural directions were issued for the applicant's release.
Issues considered
- Whether the applicant is entitled to bail despite a prior criminal record and the seriousness of the alleged offence.
- Whether the delay in lodging the FIR and lack of incriminating evidence justify granting bail.
- Whether the allegations of abetment of suicide necessitate continued custody.
- How the Supreme Court precedents in Kapil Wadhawan v. CBI and Maya Tiwari v. State of U.P. influence the bail decision.
Legislation cited
- B.N.S. — s. 108
- Indian Penal Code — s. 147, 325, 504, 506
Subjects
- bail
- false implication
- abetment of suicide
- criminal history
- overcrowded jails
- delay in FIR
- Supreme Court precedent
- conditions of bail
Judgment
HIGH COURT OF JUDICATURE AT ALLAHABAD
CRIMINAL MISC. BAIL APPLICATION No. - 39011 of 2025
Ranjeet Patel
.....Applicant(s)
Versus
State of U.P.
.....Opposite
Party(s)
Counsel for Applicant(s) : Abhijeet Singh, Abhishek Kumar
Pandey, Birendra Singh, Gulab Yadav,
Yash Pratap Singh
Counsel for Opposite Party(s) : Abhishek Saroj, Sunil Kumar Yadav,
G.A.
Court No. - 67
HON'BLE JITENDRA KUMAR SINHA, J.
1. Heard Shri Abhijeet Singh, learned counsel for the applicant, Shri
Vishal Vishwakarma, holding brief of Shri Sunil Kumar Yadav, learned
counsel for the first informant and Shri Chandra Shekhar Saran, learned
A.G.A. for the State and perused the record.
2. The instant bail application has been filed with a prayer to release the
applicant on bail in Case Crime No. 167 of 2025, under Section 108 of
B.N.S., Police Station George Town, District Prayagraj, during the
pendency of the trial.
3. Learned counsel for the applicant has submitted that the applicant has
been falsely implicated in the present case though there is no
incriminating material against him. It is further submitted that the first
information report has been lodged after delay of three months on the basis
of suspicion and the cause of death of the deceased has been shown as
antemortem head injury due to fall on the ground from a train. It is further
submitted that during investigation, it has surfaced that co-accused Jyoti
Maurya was having extramarital affair with the applicant and this fact was
known to the deceased and the co-accused Jyoti Maurya threatened her that
if she disclosed this information to anyone, she would level false
allegations against her for having illicit relation with Ankit. It is further
submitted that there is no evidence regarding abetment of suicide. It is
BAIL No. 39011 of 2025
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further submitted that till date only PW-1 is being examined and the trial is
not likely to conclude in near future. It is further submitted that the
applicant is having criminal history of one case regarding some minor
offences under Sections 325, 504, 506, 147 of I.P.C. and the applicant has
been languishing in jail since14.09.2025, in case, he is granted bail, he
will not misuse the liberty of bail and would cooperate in the trial
proceedings.
4. Per contra, learned counsel for the first informant and learned A.G.A.
have vehemently opposed the prayer for bail and it has been submitted by
them that PW-1 has stated before the learned trial Court that he had given
an application for registration of the FIR on the same day, when the
deceased disappeared and during investigation, the call detail records of
the deceased, co-accused Jyoti Maurya and Ranjit show that they were in
constant conversation.
5. Initially, the deceased went missing on 11.05.2025 and a report
regarding her missing was registered in the police station on 12.05.2025
and the first information report has been lodged after delay of three months
on the basis of suspicion and the cause of death of the deceased has been
shown as antemortem head injury due to fall on the ground from a train. It is
further submitted that during investigation, it has surfaced that co-accused
Jyoti Maurya was having extramarital affair with the applicant and this fact
was known to the deceased and the co-accused Jyoti Maurya threatened her
that if she disclosed this information to anyone, she would level false
allegations against her for having illicit relation with Ankit. It is further
submitted that there is no evidence regarding abetment of suicide. It is
further submitted that till date only PW-1 is being examined and the trial is
not likely to conclude in near future. It is further submitted that the
applicant is having criminal history of one case regarding some minor
offences under Sections 325, 504, 506, 147 of I.P.C. and the applicant has
been languishing in jail since14.09.2025.
6. Considering the entire facts and circumstances of the case, submissions
of learned counsel for the parties and keeping in view the nature of
offence, evidence, complicity of the accused and taking into account
overcrowded jails and heavy pendency of criminal cases before the trial
BAIL No. 39011 of 2025
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courts as well as considering the mandate of the judgement of the Apex
Court in the case of Kapil Wadhawan vs Central Bureau of Investigation
reported in 2025 SCC OnLine SC 3038 as well as guideline of this Court
in the case of Maya Tiwari Vs. State of U.P. reported in 2024 SCC
Online All 6765 regarding grant of bail and without expressing any
opinion on the merits of the case, I am of the opinion that the applicant is
entitled to be enlarged on bail.
7. Accordingly, the present application is ALLOWED.
8. Let the applicant- Ranjeet Patel involved in the aforementioned crime
be released on bail, on his furnishing a personal bond and two sureties
each in the like amount, to the satisfaction of the court concerned, with
the following conditions:-
(i) The applicant shall not directly or indirectly make any inducement,
threat or promise to any person acquainted with the facts of the case so as
to dissuade him from disclosing such facts to the Court or to any police
officer or tamper with the evidence.
(ii) The applicant shall cooperate in the trial/investigation sincerely
without seeking any adjournment.
(iii) The applicant shall not indulge in any criminal activity or
commission of any crime after being released on bail.
(iv) The applicant shall attend in accordance with the conditions of the
bond executed by him.
9. In case of breach of any of the above conditions, it shall be a ground for
cancellation of bail.
10. Identity, status and residence proof of the applicant and sureties be
verified by the court concerned before the bonds are accepted.
Verification of mobile number and Aadhaar card of the applicant as well
as sureties should be verified by the court concerned.
11. It is further directed that the trial court shall send the release order to
the concerned jail through Bail Order Management System (BOMS) to
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4
ensure early release of the applicant.
12. Office is directed to send a copy of this order to the applicant through
Jail Superintendent, Prayagraj via e-mail or e-prison portal within 24
hours in compliance of the order of the Apex Court in the case of Policy
Strategy for Grant of Bail, In Re: Suo Motu Writ Petition (Crl.) No.4
of 2021 decided on 31.01.2023 reported in (2024) 10 SCC 685.
(Jitendra Kumar Sinha,J.)
September 18, 2026
RKM
Digitally signed by :-
RAJESH KUMAR MAURYA
High Court of Judicature at Allahabad
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