Facts
Respondent No. 2, Vasanthamma, lodged a complaint concerning a dispute over a sale deed dated 24 January 2011 for five guntas of land in Sy. No. 24/1.
Source reference: p.3–5; para. 3, 5, 7The police registered Crime No. 114/2026 against the appellants under provisions of the Bharatiya Nyaya Sanhita, 2023 and the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, as amended
Source reference: p.3–5; para. 3, 5, 7The appellants sought anticipatory bail under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023; after the Sessions Court rejected the application, they appealed under Section 14A(2) of the SC/ST Act
Source reference: p.1, p.4; para. 1, 4They contended that the complaint arose from a civil property dispute and was falsely brought to obstruct or overcome the sale deed
Source reference: p.4; para. 5Issues
1. Whether the allegations disclosed a prima facie offence under the SC/ST Act so as to preclude anticipatory bail in the circumstances of the case
Source reference: p.4–6; para. 5, 7, 92. Whether the appellants were entitled to anticipatory bail, including in light of the investigation’s procedural status
Source reference: p.5; para. 8Law Applied
The appeal was brought under Section 14A(2) of the SC/ST Act, and the underlying application for anticipatory bail was made under Section 482 of the BNSS, 2023
Source reference: p.1, p.4; para. 1, 4The Court considered the SC/ST Act and the SC/ST (Prevention of Atrocities) Rules, 1995, noting that the investigating officer had not submitted the report required by Rule 7 within 60 days; it also noted that no notice had been issued to the appellants under Section 35 of the BNSS
Source reference: p.5; para. 8The Court relied on Hitesh Verma v. State of Uttarakhand, (2020) 10 SCC 710, and Prathvi Raj Chauhan v. Union of India, AIR 2020 SC 1036, in considering the application of the SC/ST Act to the facts
Source reference: p.5; para. 6The judgment does not set out a detailed formulation of the legal tests from those authorities.
Source reference: p.5; para. 6Reasoning
The Court considered that the alleged quarrel concerned the sale deed for the land and treated the dispute, on the material before it, as a property dispute
Source reference: p.5; para. 7It also took account of the appellants’ contention that the complaint was motivated by the property dispute and relied on the cited Supreme Court decisions
Source reference: p.4–5; para. 5–6, 9The Court further noted the absence of a Rule 7 report after 60 days and the absence of a Section 35 BNSS notice
Source reference: p.5; para. 8Considering these circumstances together, it concluded that the appellants should receive anticipatory bail
Source reference: p.6; para. 9Holding
The High Court allowed the appeal, set aside the Sessions Court’s order dated 19 August 2026, and allowed the appellants’ application under Section 482 BNSS
It directed that, in the event of arrest in Crime No. 114/2026, each appellant be released on bail on executing a self-bond of ₹50,000 with one surety for the like sum, subject to the trial court’s satisfaction. The appellants were also directed not to tamper with or threaten prosecution witnesses, to assist the investigation, and not to indulge in similar offences.
Source reference: p.6–7; order (iii)–(vi)Acts & Sections Cited
6 provisions across 3 statutes referred to in this judgment. Each provision opens on LawLens.
Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 19891
Bharatiya Nyaya Sanhita, 20233
Bharatiya Nagarik Suraksha Sanhita, 20232
Original Court PDF
RAJANNA MvsTHE STATE OF KARNATAKA
Click to open original judgment
Original judgment, available to read, download and summarize on LawLens.in
