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No Prima Facie Case Under SC/ST Act, Madhya Pradesh High Court Grants Anticipatory Bail to Bar Association President

Shivam Y.

The Madhya Pradesh High Court granted anticipatory bail to District Bar Association President Deepak Jain after finding that the call records contradicted a key allegation and no prima facie case under the SC/ST Act was made out. - Deepak Jain v. State of Madhya Pradesh

No Prima Facie Case Under SC/ST Act, Madhya Pradesh High Court Grants Anticipatory Bail to Bar Association President
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The Madhya Pradesh High Court has granted anticipatory bail to Deepak Jain, the elected President of the District Bar Association, Narmadapuram, after finding that the material placed before it did not prima facie support the allegations attracting the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act against him. The Court observed that the available call records contradicted a key allegation in the FIR and noted that the applicant was not present during the alleged assault.

Background of the Case

The case arose from Crime No. 386/2026 registered at Kotwali Police Station, Narmadapuram. According to the prosecution, a dispute erupted during a meeting of the District Bar Association office-bearers on April 17, 2026, which later escalated through exchanges in the Association's WhatsApp group.

The complainant alleged that Deepak Jain telephoned him, abused him, and warned that his sons were on their way to assault him. Later that night, the complainant claimed that Jain's sons entered his office and assaulted him, causing injuries.

Appearing for the applicant, senior counsel argued that Deepak Jain had been falsely implicated and that no active role had been attributed to him. It was further submitted that the Call Detail Records (CDRs) showed the complainant had called the applicant, contrary to the prosecution's allegation that the applicant had initiated the threatening call.

The State and the objector opposed the plea, contending that the assault had been carried out at the applicant's instance. They also argued that since provisions of the SC/ST Act had been invoked, anticipatory bail was barred.

Court's Observations

Justice Ramkumar Choubey noted that while deciding a bail application, the Court is not expected to examine the merits of the case in detail, but a prima facie assessment is necessary.

The Court found that the principal allegation against the applicant was the alleged threatening phone call. However, the Call Detail Records placed before the Court did not support that allegation.

The bench observed,

"The Call Detail Records (CDR) contradict this assertion, revealing that it was the complainant who initiated the call to the applicant. No material or evidence has been placed before this Court to demonstrate that the applicant called the complainant at the relevant time."

The Court also took note of the undisputed position that the applicant was not present at the place where the alleged physical assault occurred.

Additionally, the High Court observed that the trial court had rejected the anticipatory bail application without identifying any incriminating material or specifying any overt act attributable to the applicant.

Court's Decision

Holding that no prima facie case under the SC/ST Act was made out against Deepak Jain, the High Court allowed the anticipatory bail application without expressing any opinion on the merits of the criminal case.

The Court directed that, in the event of his arrest, the applicant be released on anticipatory bail upon furnishing a personal bond of ₹50,000 with one solvent surety of the like amount. He was also directed to comply with the conditions prescribed under Section 482(2) of the Bharatiya Nagarik Suraksha Sanhita, 2023.

Case Details:

Case Details

Case Title: Deepak Jain v. State of Madhya Pradesh

Case Number: Misc. Criminal Case No. 19533 of 2026

Judge: Justice Ramkumar Choubey

Decision Date: 22 June 2026

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