Whether Courts are permitted to undertake detailed examination of evidence at the bail stage — Held, at the bail stage, Courts are precluded from undertaking a detailed examination of evidence or rendering findings that touch upon the merits of the case — Court cannot conduct a mini trial or record conclusions that could influence the outcome of the trial — While detailed evaluation is not required, some reasoning must support the grant of bail, especially when the offence is grave — However, even in such cases, the reasoning must be confined to prima facie satisfaction, not merit based findings
Whether Courts while considering bail applications can record elaborate details that give impression of pre determining trial outcome — Held, there cannot be elaborate details recorded to give an impression that the case is one that would result in a conviction or, by contrast, in an acquittal while passing an order on an application for grant of bail
Per R. Mahadevan, J.
In Brijmani Devi v. Pappu Kumar, the Court cautioned that there cannot be elaborate details recorded to give an impression that the case is one that would result in a conviction or, by contrast, in an acquittal while passing an order on an application for grant of bail.
At the bail stage, courts are precluded from undertaking a detailed examination of evidence or rendering findings that touch upon the merits of the case. Only a prima facie assessment of the material is warranted. The court cannot conduct a mini-trial or record conclusions that could influence the outcome of the trial. In Kalyan Chandra Sarkar v. Rajesh Ranjan @ Pappu Yadav, the Court reiterated that while detailed evaluation is not required, some reasoning must support the grant of bail, especially when the offence is grave. However, even in such cases, the reasoning must be confined to prima facie satisfaction, not merit-based findings. By the impugned order, the High Court proceeded to grant bail to the accused by delving into the merits of the case and recording findings that fall within the exclusive domain of the trial Court.
IN THE SUPREME COURT OF INDIA
Criminal Appeal Nos. 3528-3534 of 2025
Decided On: 14.08.2025
State of Karnataka Vs. Darshan and Ors.
Hon’ble Judges/Coram:
J.B. Pardiwala and R. Mahadevan, JJ.
Author: R. Mahadevan, J.
Citation: 2025 KHC 6693: 2025 INSC 979, MANU/SC/1098/2025.
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