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Sudhakar vs. State Of U.P.

Final Order
Court:Allahabad High Court (Allahabad)
Judge:Hon'ble Chandra Dhari Singh
Case Status:Unknown Status
Order Date:17 Mar 2020
CNR:UPHC010528662020

AI Summary

A bail application by Sudhakar, accused of abduction and criminal intimidation under IPC Sections 363, 366, and 507, was granted by the Uttar Pradesh High Court. The applicant was accused of assisting the main accused Baijnath in taking away a victim from her paternal home, but the victim's own statement under Section 164 CrPC indicated she left willingly and subsequently married Baijnath. The court granted bail with specific conditions regarding court attendance and cooperation with trial proceedings.

Ratio Decidendi:
In cases involving abduction charges where the alleged victim's own statement recorded under Section 164 CrPC indicates she left willingly and subsequently married the main accused, and where the accused has no criminal history and has been in custody for an extended period, bail may be granted with appropriate conditions to ensure trial cooperation and court attendance, without prejudging the merits of the case.
Obiter Dicta:
The court's imposition of stringent bail conditions, including the requirement to file an undertaking not to seek adjournments, to remain present on specific dates (opening of case, framing of charge, and Section 313 statement recording), and the warning that default may be treated as abuse of bail liberty, indicates the court's concern about ensuring trial efficiency and preventing dilatory tactics.

Case Identifiers

Primary Case No:11499/2020
Case Type:Criminal Miscellaneous Bail Application
Case Sub-Type:Bail Application under Section 439 Criminal Procedure Code for Minor
Secondary Case Numbers:201600114992020, 052866/2020, 32425/2020
Order Date:2020-03-17
Filing Year:2020
Court:Uttar Pradesh High Court
Bench:Single Judge
Judges:Hon'ble Chandra Dhari Singh

Petitioner's Counsel

Ram Kesh
Advocate - Appeared

Respondent's Counsel

G.A.
Government Advocate - Appeared

eCourtsIndia AITM

Brief Facts Summary

Sudhakar was accused of helping the main accused Baijnath take away a woman from her paternal home without permission. An FIR was registered against both of them under Sections 363, 366, and 507 IPC at Police Station Bansi, Siddharth Nagar District. Sudhakar was arrested on January 5, 2020. However, when the victim was asked to give her statement to the court under Section 164 CrPC, she stated that she left her home of her own free will and was not compelled by anyone. Subsequently, the victim married Baijnath. Sudhakar, who had been in jail for over two months and had no previous criminal history, filed a bail application in the High Court.

Timeline of Events

2020-01-05

Sudhakar arrested in connection with FIR No. 2 of 2020 under Sections 363, 366, 507 IPC at Police Station Bansi, Siddharth Nagar

2020-01-05

Woman left her paternal home with Baijnath

2020-01-05 to 2020-03-17

Sudhakar remained in jail for over two months

Before 2020-03-17

Victim recorded her statement under Section 164 CrPC indicating she left willingly

Before 2020-03-17

Victim married Baijnath

2020-03-07

Bail application filed in High Court

2020-03-16

Bail application registered as Criminal Misc. Bail Application No. 11499 of 2020

2020-03-17

Bail application heard and disposed by Hon'ble Chandra Dhari Singh, J.

Key Factual Findings

The victim went with Baijnath of her own sweet will and was not compelled to leave her paternal home

Source: Recited from Victim's Statement under Section 164 CrPC

The victim and Baijnath have married each other

Source: Recited from Petitioner Pleading

Sudhakar has been in jail since January 5, 2020

Source: Recited from Petitioner Pleading

Sudhakar has no previous criminal history

Source: Recited from Petitioner Pleading

The only allegation against Sudhakar is that he helped Baijnath take away the victim from her paternal home

Source: Recited from FIR and Petitioner Pleading

Primary Legal Issues

1.Whether bail should be granted to an accused in an abduction case when the alleged victim has given a statement indicating she left willingly
2.Applicability of Section 363 IPC (Punishment for Kidnapping) when the victim's own statement contradicts the charge
3.Applicability of Section 366 IPC (Kidnapping or Abducting with Intent to Compel for Marriage) when the victim subsequently marries the main accused
4.Applicability of Section 507 IPC (Criminal Intimidation) in the context of the case facts

Secondary Legal Issues

1.Credibility and weight of victim's statement recorded under Section 164 CrPC
2.Relevance of victim's subsequent marriage to the main accused in assessing the charges
3.Conditions to be imposed on bail to ensure court attendance and trial cooperation
4.Distinction between abduction and elopement in criminal law

Questions of Law

Can bail be granted when the alleged victim's own statement contradicts the abduction charge?
What weight should be given to a victim's statement under Section 164 CrPC in bail proceedings?
What conditions should be imposed to ensure the accused's presence during trial?

Statutes Applied

Indian Penal Code
363
Kidnapping - charge against Sudhakar for allegedly helping take away the victim from her paternal home
Indian Penal Code
366
Kidnapping or Abducting with Intent to Compel for Marriage - charge related to the abduction of the woman
Indian Penal Code
507
Criminal Intimidation - charge against Sudhakar in the FIR
Criminal Procedure Code
164
Recording of statement of victim - victim's statement indicating she left willingly was recorded under this section
Criminal Procedure Code
439
Bail in criminal cases - basis for the bail application and court's authority to grant bail
Criminal Procedure Code
82
Proclamation for appearance - mentioned as consequence if bail is misused
Indian Penal Code
229-A
Failure to appear in court - consequence for non-appearance without sufficient cause
Indian Penal Code
174-A
Non-appearance in response to proclamation - consequence if bail is misused and accused fails to appear
Criminal Procedure Code
313
Statement of accused - accused must be present in person for recording of statement under this section

Petitioner's Arguments

The learned counsel for the applicant Sudhakar submitted the following arguments: (1) The only allegation against Sudhakar in the FIR is that he helped the main accused Baijnath take away the victim from her paternal home. (2) According to the victim's own statement recorded under Section 164 CrPC, she went with Baijnath of her own free will and no one compelled her to leave her paternal home. (3) The victim and Baijnath have now married each other. (4) The allegations made in the FIR are false. (5) Sudhakar has been in jail since January 5, 2020, which is over two months. (6) Sudhakar has no previous criminal history. (7) If released on bail, Sudhakar will not misuse the liberty and will cooperate with the trial.

Respondent's Arguments

The learned AGA (Additional Government Advocate) opposed the prayer for bail but did not contradict the facts presented by the applicant's counsel. The State's opposition was limited and did not provide substantive counter-arguments to the applicant's contentions regarding the victim's willingness or the false nature of the allegations.

Court's Reasoning

The court, after hearing the learned counsel for the applicant and the learned AGA, and after perusing the record, considered the facts and circumstances of the case. The court noted that: (1) The victim's own statement under Section 164 CrPC indicates she went with Baijnath willingly and was not compelled. (2) The victim and Baijnath have subsequently married. (3) The applicant has been in custody since January 5, 2020. (4) The applicant has no previous criminal history. (5) The applicant is willing to cooperate with the trial. Without expressing any opinion on the merits of the case, the court found these circumstances sufficient to grant bail. The court imposed stringent conditions to ensure the applicant's presence during trial and to prevent misuse of bail liberty.

Statutory Interpretation Method:
Purposive Interpretation - The court interpreted the bail provisions purposively to balance the right to liberty with the need to ensure trial cooperationContextual Interpretation - The court considered the context of the victim's willingness and subsequent marriage in interpreting the abduction charges
Judicial Philosophy Indicators:
  • Emphasis on Victim's Agency - The court gave significant weight to the victim's own statement indicating her willingness
  • Presumption of Innocence - The court granted bail without expressing opinion on merits, respecting the presumption of innocence
  • Balancing Liberty and Trial Efficiency - The court balanced the accused's right to bail with the need to ensure trial cooperation through stringent conditions
  • Proportionality - The court considered the length of custody (over two months) in deciding to grant bail
Order Nature:Substantive
Disposition Status:Disposed
Disposition Outcome:Allowed

Impugned Orders

Police Station Bansi
Case: 2/2020
Date: 2020-01-05

Specific Directions

  1. 1.Applicant shall file an undertaking not to seek adjournments when evidence dates are fixed and witnesses are present
  2. 2.Applicant shall remain present before trial court on each fixed date, either personally or through counsel
  3. 3.In case of absence without sufficient cause, trial court may proceed under Section 229-A IPC
  4. 4.If bail is misused and proclamation under Section 82 CrPC is issued, trial court shall initiate proceedings under Section 174-A IPC
  5. 5.Applicant shall remain present in person on dates fixed for opening of case, framing of charge, and recording of statement under Section 313 CrPC
  6. 6.Default of above conditions may be treated as abuse of bail liberty

Precedential Assessment

Persuasive (Other High Court)

This is a single judge order from the Uttar Pradesh High Court dealing with bail in an abduction case. While it does not establish binding precedent outside the jurisdiction, it provides persuasive authority on the principles of granting bail when the alleged victim's own statement contradicts the abduction charge. The order is significant for practitioners dealing with similar cases in the High Court and lower courts within UP and potentially other jurisdictions.

Tips for Legal Practice

1.In abduction cases, the victim's own statement recorded under Section 164 CrPC indicating willingness to leave carries significant weight in bail proceedings, even if the charges are serious.
2.Courts may grant bail in abduction cases where the victim has subsequently married the main accused, as this suggests the absence of any element of compulsion or criminal intimidation.
3.Stringent bail conditions, including undertakings regarding adjournments, personal presence on specific dates, and warnings about abuse of bail liberty, are commonly imposed to ensure trial cooperation and prevent dilatory tactics.
4.The length of custody (over two months in this case) is a relevant factor in deciding whether to grant bail, particularly when the accused has no criminal history.

Legal Tags

Bail application abduction case victim willingness statement Section 164 CrPCCriminal Procedure Code Section 439 bail grant abduction charges IPCAbduction case bail conditions court attendance trial cooperation requirementsVictim statement contradicting abduction charge bail application granted High CourtCriminal intimidation and kidnapping charges bail with stringent conditions imposedBail conditions undertaking adjournment trial dates Section 313 CrPC statementAbduction case where victim married accused person bail decision High CourtBail application criminal case no previous criminal history release grantedCustody duration two months bail grant proportionality criminal procedureBail conditions personal bond sureties criminal abduction case High Court

Disclaimer: eCourtsIndia (ECI) is not a lawyer and this analysis is generated by ECI AI, it might make mistakes. This is not a legal advice. Please consult with a qualified legal professional for matters requiring legal expertise.

Order Issued After Hearing

Purpose:

Disposed

Before:

Hon'ble Chandra Dhari Singh

Listed On:

17 Mar 2020

Order Text

Court No. - 87

Case :- CRIMINAL MISC. BAIL APPLICATION No. - 11499 of 2020

Applicant :- Sudhakar Opposite Party :- State of U.P. Counsel for Applicant :- Ram Kesh Counsel for Opposite Party :- G.A.

Hon'ble Chandra Dhari Singh,J.

Heard learned counsel for the applicant, learned AGA and perused the record.

The accused-applicant is involved in F.I.R. No.2 of 2020, under Sections 363, 366, 507 IPC, P.S. Bansi, District Siddharth Nagar.

Learned counsel for the applicant has submitted that in the impugned FIR, the only allegation against the present applicant is to help the main accused Baijnath to take away the victim from her paternal home. Learned counsel has submitted that as per the statement of the victim recorded under Section 164 Cr.P.C., she went with Baijnath of her own sweet will and no one has compelled her to leave her paternal home. Learned counsel has also submitted that now the victim and Baijnath had married. The allegation made in the impugned FIR is false. The applicant is languishing in jail since 05.01.2020. There is no previous criminal history of the present applicant and if the applicant be released on bail, he will not misuse the liberty of bail and will cooperate with trial.

Learned AGA has opposed the prayer for bail but not contradicted the aforesaid facts.

Taking into consideration the facts and circumstances of the case but without expressing any opinion on merits, let the applicant Sudhakar be released on bail in aforesaid first information report number on his furnishing a personal bond with two sureties each in the like amount to the satisfaction of court concerned with the following conditions:

    1. The applicant shall file an undertaking to the effect that he shall not seek any adjournment on the dates fixed for evidence and the witnesses are present in court. In case of default of this condition, it shall be open for the trial court to treat it as abuse of liberty of bail and pass orders in accordance with law.
    1. The applicant shall remain present before the trial court on each date fixed, either personally or through his

counsel. In case of his absence, without sufficient cause, the trial court may proceed against him under Section 229-A of the Indian Penal Code.

    1. In case, the applicant misuses the liberty of bail and in order to secure his presence proclamation under Section 82 Cr.P.C. is issued and the applicant fails to appear before the court on the date fixed in such proclamation, then, the trial court shall initiate proceedings against him, in accordance with law, under Section 174-A of the Indian Penal Code.
    1. The applicant shall remain present, in person, before the trial court on the dates fixed for (i) opening of the case, (ii) framing of charge and (iii) recording of statement under Section 313 Cr.P.C. If in the opinion of the trial court default of this condition is deliberate or without sufficient cause, then it shall be open for the trial court to treat such default as abuse of liberty of his bail and proceed against him in accordance with law.

Order Date :- 17.3.2020 Nishant

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Order(1) - 17 Mar 2020

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