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Allahabad High Court

RAVINDRA SINGH ALIAS CHUNNUversusSTATE OF U.P.

Decided

Holding

The court denied bail, holding that it is not appropriate to grant bail when the trial is near its conclusion after charge framing.

Summary

Ravindra Singh alias Chunnu, accused of offences under Sections 147, 148, 307, 323, 504, 506, 302 and 34 of the IPC, applied for bail while the trial was nearing its conclusion, having been in custody since 28 May 2024. His earlier bail application was rejected and a Special Leave Petition challenging that order was dismissed. The State opposed bail, and the trial court report showed that ten witnesses had already been examined, indicating the trial was at its conclusive stage. Citing the Supreme Court’s decision in X v. State of Rajasthan (2024 INSC 909), the court held that bail is ordinarily not granted after charge framing when the trial is close to completion. Consequently, the bail application was rejected, with a direction that the trial be expedited in line with other Supreme Court judgments.

Issues considered

  • Whether bail can be granted to an accused when the trial is at its conclusive stage after charge framing
  • Whether the prolonged pre‑trial detention violates the accused’s right to liberty under Article 21 of the Constitution

Legislation cited

Subjects

  • bail
  • trial delay
  • IPC offences
  • Article 21
  • pre‑trial detention
  • Supreme Court precedent
  • criminal procedure

Judgment

             HIGH COURT OF JUDICATURE AT ALLAHABAD

       CRIMINAL MISC. BAIL APPLICATION No. - 41205 of 2025

Ravindra Singh Alias Chunnu
                                                              .....Applicant(s)
                                    Versus
State of U.P.
                                                                  .....Opposite
                                                                        Party(s)

Counsel for Applicant(s)      : Ajay Singh Yadav, Diwakar Shukla,
                                Kuldip Singh Yadav
Counsel for Opposite Party(s) : G.A., Ram Lakhan Deobanshi

Court No. - 66
(Sl. No. 59 out of 116)

                          HON'BLE KRISHAN PAHAL, J.

1. List has been revised.

2. Heard Sri Diwakar Shukla, learned counsel for the applicant and Sri Ram
Lakhan Deobanshi, learned counsel for the informant as well as Sri R.P.
Patel, learned State Law Officer and perused the record.

3. This is the second bail application filed on behalf of the applicant seeking
bail in Case Crime No. 114 of 2024, under Sections 147, 148, 307, 323,
504, 506, 302, 34 of IPC, Police Station- Kishanpur, District - Fatehpur,
during the pendency of trial.

4. The first bail application of the applicant was rejected by this Court vide
order dated 9.1.2025 passed in Criminal Misc. Bail Application No. 44913
of 2024.

5. Learned counsel for the applicant has submitted that the applicant had
challenged the said order dated 9.1.2025 by filing SLP (Crl.) Diary No.
42909 of 2025 which was dismissed in limini and the applicant was granted
opportunity to apply for bail if the trial is delayed.

6. Learned counsel has also stated that the applicant is in jail since
28.05.2024, as such, the period of incarceration is about one year and ten
months. His fundamental rights enshrined under Article 21 of the
Constitution of India stands violated. In case, the applicant is released on
bail, he will not misuse the liberty of bail and shall cooperate with trial.
                                                                                               BAIL No. 41205 of 2025
                                                                      2


                                    7. Per contra, learned counsel for the informant and learned State Law
                                    Officer have vehemently opposed the bail application.

                                    8. This Court had called for a report regarding the status of trial and in
                                    compliance thereof, a report has been submitted by the Trial Court
                                    concerned on 28.01.2026. As per the said report, ten witnesses have been
                                    examined to date, as such, the trial is at its conclusive end.

                                    9. The Supreme Court in case of X vs. State of Rajasthan & Anr. reported in
                                    2024 INSC 909, has held that once the trial has commenced, it should be
                                    allowed to reach to its final conclusion, which may either result in
                                    conviction or acquittal of the accused. The bail should not be normally
                                    granted to the accused after the charge has been framed. It should also not be
                                    granted by looking into the discrepancies here or there in the deposition.

                                    10. Considering the facts and circumstances of the case, submissions
                                    advanced by learned counsel for the parties, the aforesaid judgement of
                                    Supreme Court and taking into consideration the fact that the trial is at its
                                    conclusive end as already ten witnesses have been examined coupled by the
                                    fact that the first bail application of the applicant was rejected by a
                                    coordinate Bench of this Court stood affirmed by the Supreme Court, I do
                                    not find it a fit case to release the applicant on bail.

                                    11. The bail application is, accordingly, rejected.

                                    12. However, it is directed that the aforesaid case pending before the trial
                                    court be decided expeditiously, in view of the principle laid down in the
                                    recent judgements of the Supreme Court in the cases of Vinod Kumar vs.
                                    State of Punjab 2015 (3) SCC 220 and Hussain and Another vs. Union of
                                    India (2017) 5 SCC 702, if there is no legal impediment.

                                    13. It is clarified that the observations made herein are limited to the facts
                                    brought in by the parties pertaining to the disposal of bail application and the
                                    said observations shall have no bearing on the merits of the case during trial.

                                    March 19, 2026
                                    Siddhant
                                                                                                (Krishan Pahal,J.)




Digitally signed by :-
SIDDHANT SAHU
High Court of Judicature at Allahabad


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