Prolonged Pre-Trial Incarceration In Circumstantial Evidence Case Violates Article 21: Delhi High Court

The Delhi High Court has granted bail to a man accused in an abduction-for-ransom and murder case, observing that prolonged pre-trial incarceration in a case resting on circumstantial evidence militates against the constitutional guarantee of speedy trial under Article 21 of the Constitution.Justice Anup Jairam Bhambhani granted regular bail to accused Ranjit Mehto, who had been in custody for over five years in connection with a 2021 FIR registered under Sections 364A and 365 IPC. Offences under Sections 302 and 201 IPC were later added.The prosecution case was that the deceased, Shyam Mohan Shukla, was abducted and held captive for ransom before being murdered. The accused was arrested on February 12, 2021, and the prosecution alleged that the deceased's body was later recovered at his instance from a jhuggi allegedly rented by him.Before the High Court, the accused argued that the case rested entirely on circumstantial evidence and that there was no direct material linking him to the crime. He also questioned the prosecution timeline, contending that the body had allegedly been recovered before his formal arrest, thereby casting doubt on the prosecution's theory that the recovery was made pursuant to his disclosure statement.The Court noted that the prosecution case against the petitioner rested on a chain of circumstantial evidence.Further, what weighed heavily with the Court was the fact that the accused had remained in judicial custody for about five years while only seven out of thirty prosecution witnesses had been examined so far.It is in this backdrop that the Court observed, “While the offences alleged are undoubtedly serious, prolonged pre-trial incarceration, in a case which rests on circumstantial evidence and where the trial is at a comparatively early stage, militates against the constitutional guarantee of speedy trial under Article 21 of the Constitution of India.”Reliance was placed on Union of India v. K.A. Najeeb where the Supreme Court held that the right to speedy trial under Article 21 of the Constitution must be preserved; and that the court must step-in early rather than late, to protect the right before it is defeated by the reason of prolonged undertrial incarceration. As such, the Court granted bail subject to conditions.Appearance: Ms. Tanya Aggarwal, Mr. Kamlesh Kumar Mishra and Mr. Krishna Kumar, Advocates for Petitioner; Ms. Shubhi Gupta, APP for the State. Insp. Vishwa Nath and Insp. Dharmendra Kumar, P.S.: NDRS. Mr. Arthava and Mr. Aakash Tiwari, Advocates for complainant.Case title: Ranjit Mehto v. StateCase no.: BAIL APPLN. 748/2025 Click here to read order

Prolonged Pre-Trial Incarceration In Circumstantial Evidence Case Violates Article 21: Delhi High Court

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