Lakshmanan v. State through the Deputy Superintendent of Police & Others, 2025
The judgment reinforces that bail orders must demonstrate application of mind, especially in cases involving serious offences and SC/ST victims.
Judgement Details
Court
Supreme Court of India
Date of Decision
22 December 2025
Judges
Justice B. V. Nagarathna and Justice R. Mahadevan
Citation
Acts / Provisions
Facts of the Case
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The case arose from an incident dated 24 February 2020, in which two Scheduled Caste persons were allegedly attacked.
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The attack was allegedly carried out by an unlawful assembly armed with deadly weapons, resulting in serious injuries.
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An FIR was registered under multiple provisions of the Indian Penal Code along with the SC/ST (Prevention of Atrocities) Act.
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The accused persons were granted bail in September 2020 in the attempt to murder case.
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While the accused were on bail, four of them allegedly murdered a key eyewitness, gravely impacting the prosecution.
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A second FIR under Section 302 IPC and allied provisions was registered for the offence of murder.
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Due to this misuse of liberty, the earlier bail was cancelled in March 2023, and the accused surrendered.
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Subsequently, the Madurai Bench of the Madras High Court granted fresh bail to the accused in the first case and also directed a joint trial of both cases.
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One of the surviving victims challenged this bail order before the Supreme Court, alleging arbitrariness and perversity.
Issues
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Whether the High Court failed to properly consider the victim’s objections as mandated under Section 15A(5) of the SC/ST Act?
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Whether bail could be granted despite the accused having earlier misused bail leading to its cancellation?
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Whether the High Court ignored the murder of a material eyewitness while granting bail?
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Whether the High Court failed to consider the gravity and seriousness of the offences?
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Whether the bail order suffered from perversity, arbitrariness, and non-application of judicial mind?
Judgement
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The Supreme Court allowed the appeal filed by the victim.
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The Court set aside the bail order passed by the Madras High Court.
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The Court held that the bail order was legally unsustainable.
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The accused were directed to surrender before the jurisdictional trial court within two weeks from the date of judgment.
Held
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The Supreme Court held that Section 15A(5) of the SC/ST Act guarantees a right to be heard, not a right to a favourable outcome.
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The Court found no violation of Section 15A(5) as the victim was aware of the proceedings and objections were recorded.
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The Court held that the High Court ignored prior cancellation of bail and abuse of liberty.
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The Court concluded that such omission rendered the bail order manifestly perverse and arbitrary.
Analysis
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The Supreme Court reaffirmed that personal liberty must be balanced with societal interest and fair trial.
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The Court emphasized that prior misuse of bail is a decisive factor against re-grant of bail.
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The Court criticised the High Court for ignoring the death of a key eyewitness, which threatened the fairness of the trial.
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The Court observed that merely recording criminal antecedents without analysing their relevance amounts to an empty formality.
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The judgment reinforces that bail orders must demonstrate application of mind, especially in cases involving serious offences and SC/ST victims.