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State of U.P. v. Gayatri Prasad Prajapati

Criminal Appeal · 2020 INSC 601Decided 15 Oct 2020
Criminal Appeal No. 686 of 2020
Justice Ashok Bhushan · Justice R. Subhash Reddy · Justice M.R. Shah

Background

The respondent, a former Uttar Pradesh minister, was an accused in a serious criminal case involving sections of the POCSO Act and IPC provisions relating to sexual offences. While his regular bail application remained pending, he was granted interim bail for two months by the Allahabad High Court on medical grounds, based on his ongoing treatment at a government hospital. The State of U.P. challenged this interim bail order before the Supreme Court, arguing the High Court had ignored medical board reports showing he was already receiving adequate specialist treatment at a government super-speciality hospital.

Decision Breakdown

The Supreme Court set aside the High Court's grant of interim bail, holding that the High Court had failed to consider crucial medical board reports already on record, including one confirming the respondent's conditions were being adequately managed between two government hospitals, before concluding that proper treatment was unavailable. The Court found no basis in the record for the High Court's conclusion that his treatment was inadequate or that his health was under real and imminent threat, and noted the High Court's own bail conditions (requiring him to "ordinarily reside" at a residence) were inconsistent with a genuine medical emergency justifying release. The Court made clear its ruling was confined only to the interim bail order under challenge, and would have no bearing on the separate, still-pending regular bail application before the High Court.

Lesson Learnt

Courts granting bail or interim relief on medical grounds must engage with and explain why they are departing from medical board reports already on the record; an order that overlooks relevant medical evidence can be set aside on that basis alone.

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

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