S. 194 BNSS | Inquest Report Meant Only To Note Apparent Cause Of Death, Need Not Name Assailant: Allahabad High Court

The Allahabad High Court has observed that the only purpose of inquest report prepared under Section 194 BNSS is to make a prima facie opinion about the apparent cause of death and injuries and there is no statutory requirement to mention the name of accused. A bench of Justice Arun Kumar Singh Deshwal noted thus while rejecting the bail application of a murder accused. It was the case of the accused that he was falsely implicated in a blind murder and in the initial police diary report and hospital records, it was stated that an unknown person had fired upon the deceased. It was also argued by his counsel that the first informant's father was a panch witness during the inquest, yet the inquest report mentioned an “unknown assailant” instead of the applicant. It was contended that till the time of inquest, actual name of the accused was not known and subsequently applicant was falsely nominated as the accused. The prosecution, on the other hand, strongly opposed the bail plea. The state argued that multiple witnesses saw the applicant conducting 'Reiki' of the deceased. It was submitted that the accused had made a UPI payment at a shop adjacent to the crime scene just two hours before the incident. Furthermore, it was also submitted that even a .32 bore country-made pistol was recovered at the pointing out of the applicant and this recovery was duly substantiated through videography as per Section 105 BNSS. Against this backdrop of these observations, the bench perused Section 194 BNSS to note that this provision only mandates a police officer to draw up a report regarding the apparent cause of death. This includes describing wounds, fractures, bruises and stating in what manner or by what weapon such marks appear to have been inflicted, the bench noted. Justice Deshwal also relied on the cases of Amar Singh Vs. Balwinder Singh and others 2003 and Podda Narayana vs. State of Andhra Pradesh 1975, wherein the corresponding Section 174 CrPC was interpreted and it was observed that while preparing the inquest report, there is no requirement of mentioning the name of the accused who caused the death of the person, whose body is under examination.Against this backdrop and while taking into account the gravity of the offence and the specific role assigned to the accused-applicant, the bench refused to grant him bail.Case title - Sunny vs State of UP 2026 LiveLaw (AB) 185Case Citation : 2026 LiveLaw (AB) 185Click Here To Read/Download Order

S. 194 BNSS | Inquest Report Meant Only To Note Apparent Cause Of Death, Need Not Name Assailant: Allahabad High Court

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