Bombay High Court Grants Bail to Accused in SC/ST Act Case Due to Lack of Prima Facie Evidence and Delay in Trial. Appellant, who suffered burn injuries himself, was not shown to have committed the murder or caste-based insults; co-accused already granted bail.

High Court: Bombay High Court Bench: GOA In Favour of Accused
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Case Note & Summary

The appellant, Mangesh Chandrakant Ransing, filed an 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 appellant was arrested in connection with 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), 3(1)(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 with burn injuries. The appellant initially claimed that his wife's family had poured petrol on both of them and set them on fire due to their inter-caste marriage. However, the victim later succumbed to her injuries, and the appellant was charged with her murder. The appellant argued that he was a victim himself and had no role in the incident, and that the co-accused had already been granted bail. The State opposed bail, citing the seriousness of the offences and the caste-based nature of the crime. The High Court, after examining the material on record, found that there was no prima facie evidence to show that the appellant had committed the alleged offences. The court noted that the appellant himself had sustained burn injuries and had been hospitalized. The court also considered that the trial was not likely to conclude soon and that the co-accused had been granted bail. Accordingly, the court allowed the appeal, set aside the impugned order, and directed the appellant's release on bail on certain conditions.

Headnote

A) Criminal Procedure - Bail - Section 483 BNSS, Section 14-A SC/ST Act - Grant of Bail - Appellant accused of murder and attempt to murder with caste-based insults - Court found no prima facie evidence of appellant's involvement in setting victim on fire; rather, appellant himself suffered burns - Co-accused already granted bail - Trial not likely to conclude soon - Held that appellant is entitled to bail on conditions (Paras 1-15).

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Issue of Consideration

Whether the appellant is entitled to bail under Section 483 of BNSS, 2023 read with Section 14-A of the SC/ST Act, considering the lack of prima facie evidence and the prolonged incarceration.

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Final Decision

Appeal allowed. Impugned order dated 10.09.2025 set aside. Appellant directed to be released on bail on furnishing PR bond of Rs. 25,000 with one solvent surety, subject to conditions including not tampering with evidence, not leaving jurisdiction without permission, and attending trial regularly.

Law Points

  • Bail under Section 483 BNSS
  • Section 14-A SC/ST Act
  • Prima facie case
  • Delay in trial
  • Parity with co-accused
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Case Details

2026:BHC-AUG:14896

Criminal Appeal No. 895 of 2025

2026-04-08

Y. G. Khobragade, J.

2026:BHC-AUG:14896

Adv. Shubham D. Jayabhar (for appellant), Mr. Dande (APP for State), Ms. Harsha Lomte (for respondent No. 2)

Mangesh s/o Chandrakant Ransing

The State of Maharashtra, Nirmalabai Rama Bhartiya

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Nature of Litigation

Criminal appeal against rejection of bail application under Section 14-A of SC/ST Act.

Remedy Sought

Appellant sought bail in connection with Crime No. 395/2019 for offences under IPC and SC/ST Act.

Filing Reason

Appellant was arrested and his bail was rejected by the Special Judge; he challenged the order on grounds of lack of evidence and prolonged incarceration.

Previous Decisions

The Special Judge, Ahmednagar, rejected the bail application (Exh.32) on 10.09.2025 in Special Case No. 259/2019.

Issues

Whether the appellant made out a case for bail under Section 483 BNSS read with Section 14-A of SC/ST Act. Whether there is prima facie evidence against the appellant for the alleged offences. Whether the appellant is entitled to bail on parity with co-accused who were granted bail.

Submissions/Arguments

Appellant argued that he was a victim and had no role in the incident; he himself suffered burn injuries; co-accused were granted bail; trial not likely to conclude soon. State opposed bail citing seriousness of offences, caste-based nature, and that appellant was the husband of the deceased.

Ratio Decidendi

Bail can be granted under Section 14-A of SC/ST Act if there is no prima facie case and the trial is delayed; the appellant himself was a victim and no evidence showed his involvement; parity with co-accused who were granted bail.

Judgment Excerpts

By the present Appeal under section 14-A of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, the appellant/original accused takes exception to the order dated 10.09.2025 passed by the learned Special Judge, Ahmednagar in Special Case No. 259 of 2019, thereby rejected Exh.32 an application for bail under section 483 of Bharatiya Nagarik Suraksha Sanhita, 2023.

Procedural History

On 02.05.2019, information received about burn injuries to appellant and victim. Crime No. 395/2019 registered. Appellant arrested. Bail application (Exh.32) rejected by Special Judge on 10.09.2025. Present appeal filed under Section 14-A of SC/ST Act. Heard on 06.04.2026 and judgment pronounced on 08.04.2026.

Acts & Sections

  • Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989: 3(1)(r), 3(1)(s), 3(2)(va), 14-A
  • Indian Penal Code, 1860: 302, 307, 203
  • Bharatiya Nagarik Suraksha Sanhita, 2023: 483
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