Chhattisgarh High Court

Parole may be denied based on victim safety concerns and systemic risks of prisoners absconding.

SHIV KUMAR KOSHLE @ BABLU vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: March 19, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner was convicted under Section 302 of the IPC for the murder of Priti Koshle by the 6th Addl. Sessions Judge, Bilaspur, on November 26, 2024

Source reference: p.2-3

He has been incarcerated since November 1, 2021

Source reference: p.3

While his criminal appeal (No. 525/2025) was pending, the petitioner applied for 14 days of leave on August 6, 2025, under the C.G. Prisoners Leave Rules, 1989

Source reference: p.3

Although initially recommended by the competent authority, the District Magistrate (Respondent No. 3) rejected the application on September 23, 2025

Source reference: p.3

The rejection was based on objections from the deceased's family members, who expressed fear of a recurring incident if the petitioner were released

Source reference: p.3-4

The petitioner challenged this rejection via a writ petition under Article 226 of the Constitution

Source reference: p.2
02

Issues

1. Whether the petitioner is entitled to grant of leave/parole under the C.G. Prisoners Leave Rules, 1989, in light of adverse police reports and objections from the victim's family

Source reference: p.3-4

2. Whether the high rate of absconding prisoners in the state, as noted in concurrent public interest litigation, justifies the denial of parole

Source reference: p.4-7
03

Law Applied

Rule 5(C) of the C.G. Prisoners Leave Rules, 1989, which governs the eligibility and conditions for granting leave to prisoners

Source reference: p.3

Article 226 of the Constitution of India

Source reference: p.2

WPPIL No. 33/2025 (Suo Moto PIL Vs. State of Chhattisgarh & Others), specifically regarding the trend of prisoners failing to surrender after being released on bail or parole

Source reference: p.4-5
04

Reasoning

The court evaluated the District Magistrate's order, noting that the primary ground for refusal was a legitimate apprehension of safety for the deceased's family

Source reference: para. 7

The court integrated findings from a pending Suo Moto PIL (WPPIL No. 33/2025), wherein the Director General of Police (DGP) filed an affidavit stating that 38 out of 40 prisoners released on parole remained at large

Source reference: para. 8

The court reasoned that the increasing frequency of prisoners absconding and failing to surrender post-parole, combined with the specific threat of recidivism or retaliation against the victim's family in this case, outweighed the petitioner's claim for leave

Source reference: para. 9-10

The court found that the District Magistrate had rightly exercised discretion based on the material available

Source reference: para. 5, 10
05

Holding

The Court held that given the circumstances and the broader issue of absconding convicts in the state, it was not inclined to grant the petitioner leave

The writ petition was dismissed, and the order of the District Magistrate rejecting the parole application was upheld

Source reference: para. 11
Chhattisgarh High Court

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SHIV KUMAR KOSHLE @ BABLUvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · March 19, 2026

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