The Supreme Court, in its judgment dated December 13, 2024, granted bail to the appellant, Pradeep Pandurang Mane, while expressing its strong disapproval of the trial court’s failure to frame charges and commence the trial in a case dating back to December 2016. The appellant had been accused under Sections 307 and 34 of the Indian Penal Code, 1860, as well as Section 3(25) of the Arms Act, 1959, for alleged involvement in an attempt to murder. Despite being in custody since April 2017, the trial court had not initiated proceedings to frame charges in the matter.

The bench, comprising Justice Dipankar Datta and Justice Prashant Kumar Mishra, took note of the prolonged incarceration of the appellant, observing that such delays are contrary to the principles of fair trial and the constitutional guarantee of the right to life under Article 21 of the Constitution. The court remarked, "Keeping an accused behind bars without trying him for the offence alleged against him, for long, itself is in breach of the procedure established by law and amounts to a punishment invading the right to life of such an accused."

The appellant’s plea for bail had previously been denied by the Bombay High Court on April 16, 2024, which cited the appellant’s alleged role as the main assailant and gang leader, as well as his criminal antecedents. However, the Supreme Court scrutinized the circumstances of the appellant’s alleged antecedents and noted that of the six cases against him, he had been acquitted in two, while judgment was reserved in another. In the remaining cases, two of which are triable by a Magistrate, the appellant had already been granted bail. The court remarked, "We have failed to comprehend as to why the charges could not be framed and trial commenced by the Sessions Court till now. It has been almost seven and a half years that the appellant has been languishing in jail."

The court observed that prolonged pre-trial incarceration violates the fundamental rights of the accused and undermines the integrity of the judicial system. It observed, "Justice delayed is justice denied. Such delays erode public confidence in the administration of justice and adversely impact the constitutional guarantees enshrined in Article 21."

Granting bail to the appellant, the court observed that his continued detention was unjustified, particularly given the lack of progress in the trial and the bleak prospect of its imminent conclusion. The court’s order explicitly stated, "The long incarceration of the appellant, non-framing of charges, and the prospect of imminent conclusion of the trial being bleak, we are of the considered opinion that he may be admitted to an order for bail." It directed the trial court to impose appropriate conditions to ensure the appellant’s attendance at future hearings and clarified that any breach of such conditions could result in the cancellation of bail.

The appellant was represented by advocates Sachin Patil, Sandeep Magar, Geo Joseph, Risvi Muhammad, and Rishabh Agarwal. The State of Maharashtra was represented by advocates Shrirang B. Varma, Siddharth Dharmadhikari, and Aaditya Aniruddha Pande.

Case Title: Pradeep Pandurang Mane v. State of Maharashtra

Case No: SLP (Crl.) No. 16042/2024

Bench:  Justice Dipankar Datta and Justice Prashant Kumar Mishra