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Supreme Court Cancels Bail in SC/ST Atrocity Case, Flags Witness Murder and High Court’s Failure to Consider Prior Bail Misuse

Vivek G.

Lakshmanan vs State through the Deputy Superintendent of Police & Others, Supreme Court cancels bail in SC/ST atrocity case, cites witness murder, prior bail misuse, and sets aside High Court’s joint trial direction.

Supreme Court Cancels Bail in SC/ST Atrocity Case, Flags Witness Murder and High Court’s Failure to Consider Prior Bail Misuse

The Supreme Court on Thursday stepped in to cancel bail granted to a group of accused in a violent land dispute case from Tamil Nadu, sharply criticising the High Court for overlooking crucial facts, including the murder of a key eyewitness while the accused were earlier out on bail. The ruling came after a packed hearing where victim rights, witness safety, and judicial discretion dominated the arguments.

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Background

The case traces back to February 2020, when Lakshmanan and his friend Suresh were allegedly attacked with deadly weapons while fencing agricultural land in Madurai district. Lakshmanan, who belongs to a Scheduled Caste, also alleged caste-based abuse, bringing the case under the SC/ST (Prevention of Atrocities) Act.

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While the accused were initially released on bail, the matter took a grim turn in December 2022. Suresh, the prime injured eyewitness in the first case, was allegedly murdered by some of the same accused. That incident led to cancellation of bail earlier and triggered a second criminal case. Despite this history, the Madras High Court granted bail again in April 2025 and even directed a joint trial of both cases.

Lakshmanan challenged that order before the Supreme Court of India, arguing that the accused had already shown they could misuse liberty.

Court’s Observations

A Bench of Justices B.V. Nagarathna and R. Mahadevan made it clear that while victims under the SC/ST Act must be heard during bail proceedings, “the right to be heard does not mean the court must accept every objection raised.” The Bench noted that the complainant had, in fact, been heard by the High Court.

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However, the real problem lay elsewhere. The judges observed that the High Court failed to apply its mind to decisive factors. “A determinative circumstance - the earlier cancellation of bail due to the murder of a material witness - was completely ignored,” the Bench remarked.

The Court also took exception to the High Court’s direction for a joint trial. It explained in simple terms that separate trials are the rule in criminal law, and clubbing cases is an exception that requires strict conditions. Here, the two crimes arose from different incidents, different years, and different evidence. Ordering a joint trial at the bail stage, the Bench said, was legally unsustainable.

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Decision

Setting aside the High Court’s judgment, the Supreme Court cancelled the bail granted to the accused and directed them to surrender before the trial court within two weeks. “Grant of bail ignoring prior misuse of liberty, witness intimidation, and the gravity of offences amounts to a perverse exercise of discretion,” the Bench observed, while directing that the trial proceed independently and strictly on merits.

Case Title: Lakshmanan vs State through the Deputy Superintendent of Police & Others

Case No.: Criminal Appeal of 2025 (arising out of SLP (Crl.) Nos. 6647–6650 of 2025)

Case Type: Criminal Appeal (Bail Cancellation under IPC and SC/ST (Prevention of Atrocities) Act)

Decision Date: 19 December 2025

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