No Active Role In Murder, Long Custody: Punjab & Haryana High Court Grants Bail To Woman Accused In Charis Goyal Death Case
The Punjab and Haryana High Court has granted regular bail to a woman accused in a case relating to the death of 19-year-old Charis Goyal, observing that the Special Investigation Team (SIT) did not attribute any active role to her in the alleged murder and being a female she deserves a lenient view.
In March 2025, the body of nineteen-year-old girl, who had been missing for two days, was found in a canal near Yatri village, in Punjab's Maur Mandi, following a two-day search
Justice Surya Pratap Singh noted, "that the petitioner is already in custody for a period of more than nine and half months; that as per findings recorded by SIT she was not actively involved in the commission of offence of murder of deceased; that the trial is not likely to be concluded in near future; that being a female, the petitioner deserves a lenient view; that nothing is left to be recovered from the possession of the petitioner and therefore, detention of petitioner in judicial lock-up is not likely to serve any useful purpose."
The petitioner was arrested in connection with FIR lodged on 11.03.2025, registered at Police Station Maur, District Bathinda, for offences punishable under Sections 103, 238, 239 and 249 of the Bharatiya Nyaya Sanhita, 2023 (BNS).
The FIR was lodged at the instance of Sumeet Goyal, father of the deceased Charis Goyal, a student of MCM DAV College, Sector 36, Chandigarh. It was alleged that on 09.03.2025, Charis left Chandigarh for her home at Maur Mandi but did not reach. Later that night, she allegedly informed her mother that she was locked in a room and an attempt to rape her was being made.
The complainant further alleged that Charis had been kidnapped by Mukul Mittal, Karan Bansal and two unknown persons in a Bolero vehicle. During investigation, several accused were arrested, and on 12.03.2025, Charis's dead body was recovered from the Kotla Canal Branch, following which the offence under Section 103 BNS (murder) was added.
Senior Advocate Bipan Ghai appearing for the petitioner argued that she had been falsely implicated on the basis of unreliable and inadmissible material. It was submitted that a Special Investigation Team headed by the Deputy Superintendent of Police, Bathinda (Rural) was constituted, and its findings clearly established that the petitioner was not present near the canal when the incident occurred.
Relying on SIT report, it was contended that CCTV footage and call detail records revealed that the deceased was voluntarily accompanying the main accused Mukul Mittal and was seen roaming freely with him at various locations. As per the SIT, an argument took place between Mukul Mittal and Charis Goyal near the canal, during which Mukul pushed her into the canal, resulting in her death.
It was further argued that the petitioner had already undergone more than nine and a half months of incarceration, the trial was not likely to conclude in the near future, nothing remained to be recovered from her, and she was entitled to a lenient view, particularly being a woman.
The State and the complainant, opposed the bail plea, contending that the allegations were serious in nature and involved the offence of murder. It was argued that the gravity of the offence and the role attributed to the petitioner disentitled her from the concession of bail.
After perusing the record and the SIT findings, the High Court noted that the petitioner had been in custody for over nine and a half months.
As per the SIT report, she was not actively involved in the commission of the offence of murder and the prosecution case, supported by CCTV footage and CDR analysis, indicated that the fatal incident occurred following an altercation between the deceased and Mukul Mittal alone.
It also pointed that the trial was not likely to conclude in the near future. No material was placed on record to suggest that the petitioner would tamper with evidence or influence witnesses if released on bail.
The Court placed reliance on Supreme Court judgments in Dataram Singh v. State of Uttar Pradesh (2018), Satender Kumar Antil v. CBI (2022) and Tapas Kumar Palit v. State of Chhattisgarh (2025), reiterating that “bail is the rule and jail is an exception”, and that prolonged pre-trial incarceration undermines the presumption of innocence and the right to speedy trial.
The Court also emphasised that denial of bail in cases where trials are likely to be delayed would result in grave injustice, especially if the accused is ultimately acquitted.
Consequently, the bail petition was allowed.
Mr. Bipan Ghai, Sr. Advocate with Mr. Nikhil Ghai, Advocate, Mr. Nikhil Thamman, Advocate for the petitioner.
Mr. I.P.S. Sabharwal, DAG, Punjab.
Mr. Naresh Jain, Advocate for the complainant.
Title: DIMPLE v. STATE OF PUNJAB