Case Citation:
Criminal Appeal No. ______ of 2025 (Arising from SLP (Crl.) No. 3512 of 2025), Supreme Court of India.
(Arising out of Patna High Court order dated 07-02-2025 in CRASJ No. 5508/2024)

Related Laws:

• Indian Penal Code, 1860 (IPC): Sections 147 (rioting), 148 (rioting armed with deadly weapon), 149 (unlawful assembly), 302 (murder).

• Arms Act, 1959: Section 27 (punishment for using arms).

• SC/ST (Prevention of Atrocities) Act, 1989: Section 3(2)(v) (offence leading to victim’s death).

• Code of Criminal Procedure, 1973 (CrPC): Bail provisions (Sections 439), Section 161 (record of witness statements).

Key Points of the Order:

1. Background:
   The appellant, Satyendra Rai @ Dalgira Rai, was arrested in FIR No. 44/2023 (Kudhani Police Station, Kaimur, Bihar) and had been in custody since 25th November 2024.
   Charges included murder (IPC 302), rioting (IPC 147/148/149), illegal arms use (Arms Act), and caste-based atrocity (SC/ST Act).
   The Patna High Court rejected his bail plea (07-02-2025), prompting this Supreme Court appeal.

2. Supreme Court’s Observations (14-08-2025):
   Delayed Trial: Charges were yet to be framed, and the prosecution planned to examine 14 witnesses—indicating prolonged proceedings.
   Parity with Co-Accused: 15 co-accused in the same case had already been granted bail by the High Court.
   Discrepancies in Evidence: Material contradictions existed between the FIR contents and witness statements recorded under CrPC Section 161.

3. Decision:
   The Bench (Justices Dipankar Datta and Augustine George Masih) granted bail to the appellant, setting aside the High Court’s order.
   Conditions Imposed:
   Bail terms to be decided by the trial court.
   Appellant must appear regularly before the trial court.
   Bail subject to cancellation for non-compliance or breach of conditions.

4. Critical Clarification:
   Bail grant does not signify innocence or prejudge the case’s merits.
   Observations in this order are strictly limited to bail considerations.

Summary:

The Supreme Court allowed Satyendra Rai’s bail appeal based on:

1. Parity with co-accused who were already granted bail.

2. Procedural delays (charges not framed, pending witness examinations).

3. Inconsistencies between FIR and witness statements.

The appellant’s release is conditional, and the trial court retains authority to cancel bail for non-compliance.