Karnataka HC Denies Bail To Two Men Accused In Dalit Man’s Fatal Bar Beating, Citing Risk Of Threatening Witnesses

In brief

The question

Whether the appellants should be released on bail pending trial, having regard to the materials collected during the investigation and the circumstances relied on by the parties.

The court held

The High Court dismissed both appeals

It also directed

left in place the trial court’s refusal to grant bail to the appellants

01Facts

The appellants, accused Nos. 1 and 2 in Special Case No. 48/2026, appealed under Section 14A(2) of the SC/ST (Prevention of Atrocities) Act against the order dated 22 July 2026 refusing them bail.

¶ 1–3, 8

They were arrested on 21 January 2026 and charged, following investigation, with offences under Sections 103(1), 127(1), 238 and 3(5) of the Bharatiya Nyaya Sanhita, 2023, and Section 3(2)(va) of the SC/ST Act

¶ 1–3, 8

The appellants argued, among other things, that the alleged eyewitnesses had not described the assault in their statements and that accused No. 4 had been granted bail.

¶ 4–6, 9, 11

The complainant opposed the appeals

¶ 4–6, 9, 11

02Issues

i.Whether the appellants should be released on bail pending trial, having regard to the materials collected during the investigation and the circumstances relied on by the parties.

¶ 4–10

ii.Whether the trial court’s stated ground that the investigation was complete was sufficient to warrant bail in the circumstances of the case.

¶ 12

03Law Applied

Section 14A(2) of the SC/ST Act provides the appellate route invoked to challenge the bail order; Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, was the provision under which the appellants had sought bail before the trial court.

¶ 1, 3

In considering bail, the High Court assessed the prima facie material, the seriousness of the alleged offences—including that they were punishable with death or imprisonment for life—and the possibility of interference with prosecution witnesses.

¶ 10, 12

The complainant cited State of Karnataka v. Sri Darshan, Deepak Yadav v. State of U.P. and Mahipal v. Rajesh Kumar @ Polia, but the judgment does not set out or apply specific propositions from those decisions.

¶ 6

Provisions in the judgment · 7 · Linked ones open on LawLens

Scheduled Castes and the Scheduled Tribes (Prevention of Atrocities) Act, 1989 Section 3

Bharatiya Nyaya Sanhita, 2023 Section 127 Section 103 Section 238 Section 3

Bharatiya Nagarik Suraksha Sanhita, 2023 Section 483 Section 183

04Reasoning

The Court considered the charge-sheet, witness statements, accused persons’ voluntary statements, CCTV footage and related mahazars, and found prima facie material against the appellants.

¶ 8–10

It noted that the alleged eyewitnesses had not described the assault in their recorded statements, but had placed the deceased at the relevant location; the Court nevertheless concluded that the material as a whole disclosed a prima facie case.

¶ 9–10

The grant of bail to accused No. 4 did not resolve the appellants’ applications, as the victim’s appeal against that grant remained pending.

¶ 11

The Court held that completion of the investigation, without consideration of the merits, was not by itself a valid basis for bail given the gravity of the alleged offences and the risk of threats to or tampering with prosecution witnesses.

¶ 12