Madhya Pradesh High Court
Criminal LawCriminal Procedure and Evidence

Serious knife-assault allegations and an unverified CCTV alibi warrant denial of bail.

Rajju @ Sunderlal Sahu vs The State Of Madhya Pradesh

Madhya Pradesh High CourtJUDGMENT: October 07, 20262 MIN READSOURCE JUDGMENT
Serious knife-assault allegations and an unverified CCTV alibi warrant denial of bail.. Rajju @ Sunderlal Sahu vs The State Of Madhya Pradesh. Madhya Pradesh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant sought regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, in Crime No. 529/2026, registered for offences under Sections 109(1) and 3(5) of the Bharatiya Nyaya Sanhita, 2023.

Source reference: para. 2–4

The prosecution alleged that, on 15 May 2026, the applicant and two others assaulted the complainant and his cousin with a knife.

Source reference: para. 2–4

The applicant, arrested on 20 May 2026, denied involvement and relied on longstanding hostility between the families, earlier criminal cases, and CCTV footage said to place him at a temple at the time of the incident.

Source reference: para. 2–4

He also cited his age and medical condition.

Source reference: para. 2–4

The State opposed bail, submitting that the allegations were serious and that the alibi required verification.

Source reference: para. 2–4
02

Issues

Whether the applicant should be released on regular bail under Section 483 BNSS, having regard to the nature of the alleged knife assault and the material available at this stage.

Source reference: para. 5–6

Whether the applicant’s claims of false implication due to prior enmity and of being elsewhere, supported by submitted CCTV material, justified bail before that material was properly examined.

Source reference: para. 5
03

Law Applied

Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, empowers the Court to consider an application for regular bail.

Source reference: no citation

The alleged offences were under Sections 109(1) and 3(5) of the Bharatiya Nyaya Sanhita, 2023.

Source reference: no citation

In assessing bail, the Court considered the nature of the allegations, the role attributed to the applicant, and the material available on record.

Source reference: no citation

It observed that prior enmity may furnish a basis for false implication but may also provide a motive for the alleged occurrence; likewise, a pen drive or representations containing CCTV material cannot, without proper examination, conclusively establish an alibi.

Source reference: para. 5

No precedent was cited.

Source reference: no citation
04

Reasoning

The Court treated the alleged knife assault and the specific role attributed to the applicant as relevant considerations.

Source reference: para. 5–6

It declined to regard prior hostility as sufficient, by itself, to establish false implication, noting that it could also support the prosecution’s allegation of motive.

Source reference: para. 5–6

The CCTV-based alibi had not been properly examined, and its submission therefore did not conclusively establish the applicant’s absence from the scene.

Source reference: para. 5–6

On the material then available, the Court was not persuaded to grant bail.

Source reference: para. 5–6
05

Holding

The Court rejected the applicant’s first application for regular bail under Section 483 BNSS, holding that bail was not warranted at that stage in light of the nature of the allegations and the material available on record.
06

Acts & Sections Cited

6 provisions across 2 statutes referred to in this judgment. Each provision opens on LawLens.

Bharatiya Nagarik Suraksha Sanhita, 20231

Madhya Pradesh High Court

Original Court PDF

Rajju @ Sunderlal SahuvsThe State Of Madhya Pradesh

Madhya Pradesh High Court · October 07, 2026

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