Irfan vs State of Uttar Pradesh 2025 INSC 1012 - Bail

The Supreme Court set aside Allahabad HC order that granted bail to an accused solely on the ground that further incarceration will deprive the accused from an effective defence strategy.

Note

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Read Judgment

Bail - Allahabad HC in Prabhat Gangwar vs. State of U.P. observed: In an application for grant of bail, the Court is competent to set an accused on liberty in order to afford him an opportunity to frame his defence and gather evidence, to enable him to refute the prosecution case and establish his innocence. However, the Court cautioned that such liberty on the said ground cannot be applied mechanically and would require to be considered in the facts and circumstances of each case - On this, SC observed: The view expressed in Prabhat Gangwar (supra) may be applied in rare cases but that too would have to be considered in the light of the observations made therein [Context: SC set aside Allahabad HC order that granted bail to an accused solely on the ground that further incarceration will deprive the accused from an effective defence strategy]

Case Info


Case Name and Neutral Citation

  • Case Name: Irfan v. State of Uttar Pradesh & Anr.
  • Neutral Citation: 2025 INSC 1012

Coram (Judges)

  • Justice Vikram Nath
  • Justice Sandeep Mehta

Judgment Date

  • August 18, 2025

Caselaws and Citations Referred

  • Prabhat Gangwar vs. State of U.P.
    • Criminal Misc. Bail Application No. 2586 of 2023 (Allahabad High Court)
    • The judgment quotes and relies on reasoning from this case regarding bail for preparing defence and gathering evidence.

Statutes/Laws Referred

  • Indian Penal Code, 1860
    • Sections 147, 148, 302, 304, and 34
  • Code of Criminal Procedure, 1973
    • Section 313 (Recording statement of accused)