Mentioning the name of the accused in an inquest report is not a statutory requirement.

The applicant sought bail regarding Case Crime No. 100 of 2025, involving charges under Sections 103(1) (Murder) and 61(2) (Criminal Conspiracy) of the Bharatiya Nyaya Sanhita (B.N.S.), and Sections 3/25/27 of the Arms Act.

The prosecution alleged the applicant shot the deceased at a housing society gate.

The applicant argued that the case was a "blind murder" because the initial General Diary (G.D.) report, hospital records, and the inquest report—signed by the deceased's father—all referred to "unknown" assailants.

The defense further highlighted that the applicant was a witness in a separate murder case where the deceased was an accused.

The State opposed bail, citing UPI payment records placing the applicant near the scene for 'reiki' shortly before the incident, eye-witness statements, and the recovery of a .32 bore pistol videographed under Section 105 of the BNSS.

Whether it is legally necessary to mention the name of the accused in the inquest report of the deceased?

Section 194 of the Bharatiya Nagarik Suraksha Sanhita (BNSS) [formerly Section 174 Cr.P.C.], which mandates that an inquest report focus solely on the apparent cause of death and the description of wounds, fractures, or injuries.

Supreme Court precedents in Amar Singh v. Balwinder Singh and others (2003) and Podda Narayana & Ors. v. State of Andhra Pradesh (1975), which established that the details of the assault or the names of the accused are "foreign to the ambit and scope" of inquest proceedings.

The court reasoned that the statutory intent of Section 194 BNSS is limited to ascertaining the prima facie cause of death (suicidal, homicidal, accidental, etc.) and documenting physical marks of injury.

It held that there is no requirement to record the manner of the incident or the names of the assailants in the inquest report; thus, their omission does not weaken the prosecution's case.

Applying this to the facts, the court found that although the applicant’s name was missing from the initial inquest, other incriminating factors were present: his presence was digitally corroborated by a UPI payment near the scene at 3:30 P.M., multiple witnesses identified him as the shooter at 5:30 P.M., and the murder weapon was recovered using mandatory videography under Section 105 BNSS.

Finding substantial evidence of the applicant's involvement and considering the gravity of the offense, the court rejected the bail application.