The Supreme Court cancelled the bail granted by the High Court, holding that the order was perverse and suffered from non-application of mind to material facts, including the gravity of the offence and prima facie evidence. The Court reiterated that bail in serious offences like murder requires careful consideration of the allegations, evidence, and risk of witness tampering, and cannot be granted mechanically.
Facts Of The Case:
The case arose from the brutal murder of Renukaswamy, a resident of Chitradurga, whose body was discovered near an apartment in Bengaluru on June 9, 2024. The prosecution alleged that the murder was a result of a criminal conspiracy orchestrated by actor Darshan (A2) and his partner, Pavithra Gowda (A1), after the deceased had sent obscene messages to A1’s Instagram account. The conspiracy involved luring the victim from Chitradurga to Bengaluru under false pretenses, where he was abducted, held captive in a shed, and subjected to extensive torture by a group of accused, leading to his death. The post-mortem report detailed 39 injuries, including 17 fractured ribs. Seventeen individuals were charge-sheeted for offences including murder, criminal conspiracy, kidnapping, and destruction of evidence. After their bail applications were rejected by the Sessions Court, the Karnataka High Court granted bail to seven accused, including A1 and A2. The State of Karnataka appealed this decision to the Supreme Court.
Procedural History:
The procedural history began with the registration of an FIR for murder against unknown persons. After investigation, 17 accused were charge-sheeted. The Sessions Court, Bengaluru, rejected the bail applications of the seven respondents. They then approached the Karnataka High Court under Section 439 CrPC, which granted them bail vide its order dated December 13, 2024. The State of Karnataka, aggrieved by this order, filed Special Leave Petitions before the Supreme Court. The Supreme Court granted leave and, in its judgment dated August 14, 2025, allowed the state’s appeals, setting aside the High Court’s order and cancelling the bail granted to the respondents.
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Court Observation:
The Supreme Court observed that the High Court’s bail order was legally unsustainable as it was passed without due application of mind to material facts, including the heinous nature of the offence under Section 302 IPC and the prima facie evidence of conspiracy. The Apex Court held that the High Court erred by undertaking a detailed appreciation of evidence and witness credibility, which is impermissible at the bail stage. It further emphasized that procedural lapses in arrest, absent demonstrable prejudice, cannot be a determinative ground for bail in serious offences. The Court also noted the accused’s influential status and the real apprehension of witness tampering, concluding that the grant of bail undermined the sanctity of the judicial process.
Final Decision & Judgement:
The Supreme Court allowed the appeals filed by the State and set aside the impugned order of the High Court dated December 13, 2024. Consequently, the bail granted to all respondents was cancelled, and they were directed to be taken into custody forthwith. The Court mandated an expeditious trial, clarifying that its observations were confined solely to the bail decision and should not influence the trial on its merits. The judgment reinforced that bail in serious, heinous offences cannot be granted mechanically and must consider the gravity of the accusation, the strength of prima facie evidence, and the potential for undermining the trial process.
Case Details:
Case Title: State of Karnataka vs. Sri Darshan etc. Citation: 2025 INSC 979 Criminal Appeal No.: Criminal Appeal Nos. 3528-3534 of 2025 Date of Judgement: August 14, 2025 Judges/Justice Name: Justice R. Mahadevan and Justice J.B. Pardiwala