Delhi High Court

Gravity of Offence and Potential Witness Intimidation Preclude Bail Despite Prolonged Incarceration in Murder Case

Gulab v. State BAIL APPLN. 1366/2024 & CRL.M.(BAIL) 653/2024

Delhi High CourtJUDGMENT: no citation2 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant, Gulab, sought regular bail in a case arising from FIR No. 400/2020 (PS Shahbad Dairy) involving charges of murder and attempted murder.

Source reference: no citation

According to the prosecution, on the night of the incident, the applicant and co-accused Amit apprehended the victim, Abhishek, and the complainant.

Source reference: p. 2, para 4

The applicant, armed with a country-made pistol, allegedly shot Abhishek dead and subsequently shot the complainant in the shoulder when he attempted to flee.

Source reference: p. 2, para 4

The applicant has been in custody for approximately five and a half years.

Source reference: p. 3, para 5

He argued for bail on the grounds of parity with a co-accused (Ajay) and the allegedly slow pace of the trial.

Source reference: p. 2, para 5
02

Issues

Whether the applicant is entitled to regular bail on the grounds of prolonged incarceration and the slow pace of the trial.

Source reference: p. 3, para 7-8

Whether the gravity of the offence and potential threat to witnesses outweigh the applicant's right to bail.

Source reference: p. 3, para 6 & 9
03

Law Applied

The court considered Sections 302 (murder), 307 (attempt to murder), and 34 (common intention) of the Indian Penal Code (IPC), alongside Sections 25/27/54/59 of the Arms Act.

Source reference: p. 1, para 1

The court applied the principle that while the period of detention is a factor, the gravity of the offence—specifically where the punishment can extend to death—and the conduct of the accused in potentially delaying the trial or threatening witnesses are paramount considerations in bail jurisprudence.

Source reference: p. 3, para 6-7
04

Reasoning

The court rejected the applicant's contention regarding a "slow trial," noting that the applicant himself had clogged the proceedings by filing multiple applications, including jail transfer requests and a parallel interim bail application in the trial court.

Source reference: p. 3, para 7

The court observed that the trial was being conducted diligently and the delay was not attributable to the State.

Source reference: p. 3, para 7

Regarding the merits, the court emphasized the "severity of the offence" and the "gravity of the offence" where one person was killed and another injured by gunfire.

Source reference: p. 3, para 6 & 9

Furthermore, the court took note of the State’s apprehension that the applicant might threaten the injured eyewitness who is yet to be examined, and the Nominal Rolls which indicated serious charges against the applicant even while in jail.

Source reference: p. 3, para 6
05

Holding

The court held that this was not a fit case for the grant of bail due to the extreme gravity of the offences (shooting two individuals) and the risk posed to witnesses.

The court dismissed the bail application and the accompanying CRL.M.(BAIL) 653/2024.

Source reference: p. 4, para 9

The Jail Superintendent was directed to communicate this order to the applicant.

Source reference: p. 4, para 10
Delhi High Court

Original Court PDF

Gulab v. State BAIL APPLN. 1366/2024 & CRL.M.(BAIL) 653/2024

Delhi High Court · no citation

Click to open original judgment

Original judgment, available to read, download and summarize on LawLens.in

Click to open original judgment