The High Court of Jharkhand at Ranchi Bench has declined bail in a case concerning an IED (planting explosive) attack that killed three police personnel. The renewed plea principally rested on approximately five-and-a-half years of incarceration and probable trial delay, after an earlier bail appeal had been dismissed on merits. The Court acknowledged the Supreme Court’s clarification that even under the UAPA, “bail is the rule and jail is the exception”, while recognising that bail may be denied on the particular facts.
The Court relied on the prosecution’s reduction of its witness list from 169 to 97, with 45 witnesses examined, and the prima facie allegation of knowingly supplying pipes for the IED. The Court considered the prima facie allegation that Munda knowingly supplied iron pipes used to fabricate the IED involved in the attack that killed three police personnel. The seriousness of that accusation, coupled with trial progress, weighed against granting bail at this stage.
Briefly, Mangal Munda appealed against the NIA Special Court’s order dated 21 January 2026 rejecting his renewed application for regular bail. The case concerns an IED blast at Lanji Forest Hill on 4 March 2021, in which three security personnel were killed and others injured. The NIA alleged that Munda knowingly supplied iron pipes to CPI (Maoist) cadres for making IEDs and participated in the conspiracy behind the attack. His earlier bail appeal had been dismissed on merits on 12 March 2024. In the present appeal, he principally relied on prolonged custody of approximately five-and-a-half years and the alleged delay in completing the trial.
The Division Bench comprising Justice Sujit Narayan Prasad and Justice Arun Kumar Rai observed that the appellant’s alleged role had already been examined in the earlier bail proceedings, leaving prolonged incarceration and probable trial delay as the principal issues in the renewed appeal. The Court acknowledged the protection of personal liberty under Article 21 and the Supreme Court’s clarification that even under the UAPA, “bail is the rule and jail is the exception”, subject to the facts of an appropriate case.
However, it found that the prosecution had shown diligence by reducing its witness list from 169 to 97, with 45 witnesses already examined. It weighed that progress against the prima facie allegation that Munda knowingly supplied pipes used to fabricate the IED involved in the fatal attack.
The Court held that prolonged incarceration or trial delay does not, by itself, justify bail in a UAPA prosecution involving grave allegations. The Article 21 claim must be assessed alongside the restriction under Section 43D(5), the accused’s alleged role, the prima facie material and the prosecution’s diligence in progressing the trial.
