Magistrate lacks jurisdiction to grant bail in life-imprisonment cases without recording specific reasons negating prima facie guilt.

The Applicant challenged the order dated 29th January 2026 passed by the Additional Sessions Judge, Pune, which cancelled the bail previously granted to him by the Judicial Magistrate First Class (JMFC) on 19th August 2025.

The Respondent No. 2 (Complainant) alleged that the Applicant extorted ₹2,00,000 and demanded a further ₹21,00,000 by threatening to file false cases under the SC/ST (Prevention of Atrocities) Act.

During the investigation, WhatsApp chats and transcripts corroborated the extortion threats.

Additionally, the prosecution pointed out that the Applicant has a criminal history of eight other FIRs.

The Sessions Court cancelled the bail on the grounds that the JMFC lacked jurisdiction once Section 111(3) of the Bharatiya Nyaya Sanhita (BNS), 2023—pertaining to organized crime—was invoked.

1. Whether the learned Magistrate had the jurisdiction to grant bail in a case involving Section 111(3) of the BNS, 2023, where the punishment extends to life imprisonment.

2. Whether the bail granted by the JMFC was perverse and liable for cancellation due to non-consideration of the nature of the offence and the criminal antecedents of the Applicant.

The Court applied Section 111(3) of the Bharatiya Nyaya Sanhita (BNS), 2023, which defines and penalizes organized crime with a minimum of five years' imprisonment extending up to life.

It heavily relied on the precedent set by the Supreme Court in Prahlad Singh Bhati v. NCT, Delhi Anr., which stipulates that while there is no absolute legal bar, a Magistrate should generally not grant bail in cases exclusively triable by a Court of Sessions or those punishable by death or life imprisonment unless they specifically negate reasonable grounds for believing the accused is guilty.

The Court also assessed the parameters for bail cancellation rooted in the principles of "perversity" and "non-application of mind" regarding the gravity of the offence and the character of the accused.

The Court found the JMFC’s order dated 19th August 2025 to be "totally illegal and perverse" because it completely ignored the addition of Section 111(3) of the BNS, which had been invoked on 6th August 2025.

Under the Prahlad Singh Bhati doctrine, a Magistrate exercising jurisdiction in life-imprisonment cases must recording a satisfaction that no reasonable grounds exist to believe the accused is guilty; the JMFC failed to record any such satisfaction.

On merits, the High Court observed that the WhatsApp transcripts provided strong prima facie evidence of extortion.

The Court further analyzed the Applicant's conduct, noting he had been absconding, had nine total FIRs against him, and attempted to mislead the Court regarding a Supreme Court transfer petition to delay the hearing.

Consequently, the gravity of the "organized crime" and the risk of the Applicant absconding outweighed any arguments for liberty.

The High Court dismissed the Criminal Application, upholding the Sessions Court's order to cancel the bail.

The Court further refused to grant any interim protection or stay on the order, citing the Applicant's habitual criminal nature and the high likelihood of him absconding.