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No Bail Stage Trial: Supreme Court Upholds Procedural Integrity, Strikes Down Observations on Merits at Bail Stage

No Bail Stage Trial: Supreme Court Upholds Procedural Integrity, Strikes Down Observations on Merits at Bail Stage

Pradeep Mittal vs State of UP and Anr. [Order dated 4 November 2025]

Bail Stage Procedure

The Supreme Court allowed the appeals by setting aside the Allahabad High Court’s bail order, and granted liberty to the accused to again approach the High Court or Trial Court for bail consideration without being influenced by prior observations.

The appeals arose from a criminal case involving multiple accused persons, including the petitioner, related to a crime where the prosecution relied on circumstantial evidence such as mobile phone locations and recovery of certain items. The accused had challenged their detention and sought bail.

The Allahabad High Court passed an order on 7 March 2025, granting bail on the basis of perceived insufficiency of evidence linking the accused directly to the crime. The instant appeal challenged this order, contending that the High Court had improperly entered into examination of the merits at the bail stage.

The case is related to the abduction of a young university student from Bennett University, whose body was later recovered near Amroha. Prosecution evidence indicated connection between accused persons via mobile phone location tracking and recovery of the dead body near Bennett University.

Despite these facts, the accused were granted bail as the High Court held that at that stage, mere recovery of evidence or linkage through mobile phones could not conclusively prove involvement in the crime.

The Supreme Court bench comprising Justice Nongmeikapam Kotiswar Singh and Justice Manmohan concurred with the petitioners and observed that the High Court had entered into merits at the stage of bail consideration. The Court acknowledged that bail decisions must not conclusively determine guilt or innocence at a premature stage.

The Supreme Court disposed of the appeals by quashing the bail order and granting the accused liberty to re-apply for bail at the appropriate forum without influence from prior observations in either court.


Appearances:

For Petitioner(s): Mr. Siddharth Aggarwal, Sr. Adv., Mr. Karan Dhalla, Adv. Mr. Harish Malik, Adv. Mr. B. Shravanth Shanker, AOR

For Respondent(s): Mr. Manish Kumar Vikkey, AOR, Mr. Loveleen Kaithwas, Adv. Mr. Kanchan Kumar Jha, Adv. Mr. Abhishek Ravi, Adv.

Dr. Vijendra Singh, AOR, Mr. Ajay Singh, Adv. Mr. Aniket Tiwari, Adv. Mr. Sanjeev Kumar Choudhry, Adv. Mr. Raju Sonkar, Adv. Mrs. Pooja H Sonkar, Adv. Mr. Vikrm A Seth, Adv. Mr. L.n. Sharma, Adv. Mr. Ankit Kumar Shiv, Adv. Mr. Rajender Kumar, Adv. Mr. Manoj Kumar Rai, Adv. Mr. Sunil Prakash Sharma, AOR

Mr. Ardhendumauli Kumar Prasad, Sr. Adv., Mr. Saurav Sharma, Adv. Ms. Vanya Gupta, AOR, Mr. Savyasachi, Adv. Mr. Abhinav Chauhan, Adv. Mr. Shivendra Singh, Adv. Mr. Siddharth Srivastava, Adv. Mr. Sidak Kalra, Adv.

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Pradeep Mittal vs State of UP and Anr.

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