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P. Krishna Mohan Reddy v. The State of Andhra Pradesh

Special Leave Petition (Criminal) · 2025 INSC 725Decided 16 May 2025
SLP(Crl) No.-007532 - 2025 (with connected SLP(Crl) Nos. 7533 & 7534 of 2025)
Justice J.B. Pardiwala · Justice R. Mahadevan

Background

The petitioners, former public servants of Andhra Pradesh, were named in an FIR alleging a large liquor-policy scam in which certain established liquor brands were allegedly squeezed out of the market in favour of new, favoured brands, with kickbacks running into several thousand crores of rupees. The Andhra Pradesh High Court had refused them anticipatory bail, finding a strong prima facie case, and they approached the Supreme Court challenging that refusal.

Decision Breakdown

The Supreme Court declined to interfere with the High Court's refusal of anticipatory bail, holding that the allegations were serious, the investigation was at a crucial stage, and anticipatory bail is not to be granted as a matter of routine absent exceptional circumstances. The Court went on to lay down a detailed framework on how courts should treat a co-accused's police statement under Section 161 CrPC at the bail stage - distinguishing confessions, admissions and exculpatory statements, and holding that an accused's statement generally cannot be used against a co-accused except in narrow, trial-stage circumstances under Section 30 of the Evidence Act. It also directed the investigating agency not to use third-degree methods or coercion against witnesses or co-accused, warning that any such complaint would be taken seriously.

Lesson Learnt

Anticipatory bail is an extraordinary remedy, not a routine entitlement, especially where investigation into serious economic offences is still underway; and a co-accused's own statement to police generally cannot be held against another accused person at the bail stage.

Official source (sci.gov.in)View Judgment (PDF)

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