Bail granted where medical and DNA evidence fail to substantiate allegations of forceful sexual assault.

The appellant challenged an order dated January 19, 2026, passed by the Special Judge (SC/ST Act), Sagar, which rejected his bail application filed under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023

The complainant, a 28-year-old married woman, alleged that the appellant committed rape against her on December 1, 2025, and again on December 9, 2025, the latter occurring when her husband allegedly caught them

The appellant was arrested on January 3, 2026, in connection with Crime No. 647/2025

The appellant argued that the relationship was consensual and only became an accusation of rape once discovered by the husband

Investigation is complete, and a final report has been submitted

1. Whether the trial court erred in rejecting the bail application despite medical and forensic evidence failing to corroborate the complainant's allegations

2. Whether the appellant satisfies the criteria for release on bail pending trial under the Bharatiya Nagarik Suraksha Sanhita and the SC/ST Act

Section 14-A(1) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, governing appeals against bail orders

Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, regarding the grant of bail

Sections 64(2)(m) and 331(6) of the Bharatiya Nyaya Sanhita (BNS), 2023, and Sections 3(1-w)(i) and 3(2)(v) of the SC/ST Act

Section 15-A of the SC/ST Act regarding victim notification

The court found that the medico-legal examination and DNA reports prima facie did not support the allegations of forceful penetrative sexual assault

It noted that the investigation is complete, meaning the appellant’s custody is no longer required for interrogation

The court evaluated the appellant’s personal circumstances—a 40-year-old agriculturist with family dependencies and no prior criminal record—and determined there was no substantial risk of him fleeing justice or committing recidivism

The court observed that the trial would take considerable time to conclude, and there was no evidence suggesting the appellant would tamper with witnesses or evidence

The court held that the trial court's refusal of bail was erroneous given the specific facts and forensic results

The court ordered the appellant’s release on bail upon furnishing a personal bond of Rs. 50,000 with one solvent surety of the same amount

This release is subject to conditions including regular court attendance, a prohibition on committing similar offences, and a strict injunction against tampering with evidence or threatening witnesses

The order remains effective until the conclusion of the trial unless breached