Case Note & Summary
The appellant, Mangesh Chandrakant Ransing, filed a criminal appeal under Section 14-A of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, challenging the rejection of his bail application by the Special Judge, Ahmednagar, in Special Case No. 259 of 2019. The case arose from Crime No. 395 of 2019 registered at Parner Police Station for offences under Sections 302, 307, 203 of the Indian Penal Code, 1860, and Sections 3(1)(r)(s) and 3(2)(va) of the SC & ST Act. The prosecution alleged that on 02.05.2019, the appellant and his wife, Rukhmini, were admitted to Sassoon Hospital, Pune, with burn injuries. The appellant initially stated that his wife had sustained self-burn injuries at her parental house, but later claimed that on 01.05.2019, when he visited his in-laws' house, the victim's father, maternal uncle, and others poured petrol on him and his wife and set them on fire. The appellant himself suffered 40% burns. The trial court rejected bail citing the bar under Section 14-A of the SC & ST Act. The High Court examined the material on record and found that the appellant was himself a victim and had suffered burn injuries. The court noted that the appellant's statement implicated others, and there was no evidence that the appellant committed any act with caste-based intent. The court held that the bar under Section 14-A applies only if a prima facie case exists, and in this case, no prima facie case was made out against the appellant. The court also considered the prolonged incarceration since 2019 and the fact that the trial had not commenced. Consequently, the court allowed the appeal, set aside the impugned order, and granted bail to the appellant on certain conditions.
Headnote
A) Criminal Law - Bail - Section 483 BNSS, Section 14-A SC/ST Act - Prima Facie Case - The appellant sought bail in a case involving offences under Sections 302, 307, 203 IPC and Sections 3(1)(r)(s) & 3(2)(va) of SC & ST Act. The court held that the bar under Section 14-A of the SC/ST Act applies only if a prima facie case exists. Since the appellant was himself a victim of burn injuries and the prosecution's case was based on his own statement which implicated others, no prima facie case was made out against him. Bail granted. (Paras 1-15) B) Criminal Law - Atrocities Act - Caste-Based Intent - Sections 3(1)(r)(s) & 3(2)(va) SC/ST Act - The court observed that the alleged incident occurred in a domestic setting and there was no evidence that the appellant committed any act with caste-based intent. The appellant belonged to the same caste as the victim, and the allegations were primarily against the victim's family members. Held that the ingredients of the SC/ST Act were not attracted. (Paras 10-12) C) Criminal Law - Bail - Delay in Trial - Section 483 BNSS - The appellant had been in custody since 2019 and the trial had not commenced. The court considered the prolonged incarceration and the fact that the appellant was not the main accused. Held that continued detention would be unjust, and bail was granted on conditions. (Paras 13-15)
Issue of Consideration
Whether the appellant is entitled to bail under Section 483 of Bharatiya Nagarik Suraksha Sanhita, 2023, considering the bar under Section 14-A of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, and whether a prima facie case exists against the appellant.
Final Decision
Appeal allowed. Impugned order dated 10.09.2025 set aside. Appellant directed to be released on bail on executing PR bond of Rs. 25,000 with one solvent surety. Conditions: not to tamper with evidence, not to contact witnesses, attend trial regularly, and not leave jurisdiction without court permission.
Law Points
- Bail under Section 483 BNSS
- Prima facie case under SC/ST Act
- Caste-based intent
- False implication
- Delay in trial
