Prolonged custody and completed investigation justified conditional bail despite SC/ST Act allegations.

The appellant was accused of assaulting Sunanda with an axe and abusing her by referring to her caste during a dispute over raising a compound wall between their houses.

The incident allegedly occurred on 4 March 2026; the appellant was arrested the next day.

His application for regular bail was rejected by the Special Court on 28 March 2026, and he appealed under Section 14A(2) of the SC/ST (Prevention of Atrocities) Act.

By the time the appeal was considered, the investigation was complete, the charge-sheet had been filed, and the appellant had been in judicial custody for about six and a half months.

1. Whether the appellant had established sufficient grounds to set aside the Special Court’s order rejecting bail and to be released on bail.

The appeal was brought under Section 14A(2) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989.

The alleged offences included Sections 109(1), 118(2), 351(3) and 352 of the Bharatiya Nyaya Sanhita, 2023, and Sections 3(1)(s), 3(2)(va) and 3(2)(v) of the SC/ST (Prevention of Atrocities) Act.

The Court applied the general bail assessment reflected in its consideration of the allegations, nature of the injuries, period of custody, completion of investigation and filing of the charge-sheet; it cited no precedents.

The Court noted that the allegations arose from a compound-wall dispute and that the medical records showed lacerated wounds on the injured person’s parietal and occipital regions.

It did not assess the evidence or merits in detail, but considered the nature of the injuries alongside the appellant’s period in custody and the fact that the investigation was complete and the charge-sheet filed.

The complainant’s and State’s concerns about possible threats or harm could, in the Court’s view, be addressed through stringent bail conditions.

It directed the appellant’s release on bail on a personal bond of ₹1,00,000 with two sureties for the like sum, subject to conditions including non-interference with witnesses, attendance at trial, restrictions on leaving the jurisdiction, and no entry into or interference with the complainant’s or injured persons’ residence or possession.