On June 16, 2025, the Supreme Court granted anticipatory bail to former Principal District and Sessions Judge of Dimapur, Nagaland, Inalo Zhimomi, who is facing serious allegations of misusing bail money in several pending criminal cases.
A two-judge bench of Justice Ujjal Bhuyan and Justice Manmohan, after hearing the petition, granted anticipatory bail to Judge Inalo Zhimomi on the condition that he has to fully cooperate in the ongoing investigation till the Gauhati High Court takes a final decision on the matter.
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“Since the High Court has deemed it fit to call for the case diary for further investigation, we are of the view that the petitioner should have been granted the benefit of pre-arrest bail till the matter is decided by the High Court,” — Supreme Court, order dated June 16, 2025
According to the prosecution, Judge Inalo Zhimomi misappropriated ₹14,35,000 from the cash bail amount pertaining to 28 pending criminal cases. This amount was recorded in the bail register for the year 2024. Following these findings, an FIR was registered under Sections 316(4)/(5), 377 and 3(5) of the Indian Code of Criminal Procedure, 2023, pursuant to a letter from the present Principal District Judge of Dimapur and directions from the High Court.
However, Judge Inalo Zhimomi has denied the allegations, claiming that she had earlier raised concerns over the lack of procedural integrity in handling bail funds in Nagaland. In a letter to the protocol judge of the high court in 2013, he pointed out that unlike the courts in Assam, courts in Nagaland do not deposit bail money in the district treasury - which he termed a "serious concern".
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He argued that he was being unfairly targeted and due process was not followed. On being posted as district and sessions judge in Mon district in 2024, Judge Inalo Zhimomi was suspended and asked to show cause why disciplinary action should not be initiated against him under the Nagaland Service (Discipline and Appeal) Rules, 1967.
Subsequently, an order dated March 25, 2025, issued by the Registrar (Vigilance), imposed compulsory retirement on him under Rule 20(2) of the Nagaland Judicial Service Rules, 2006. This was followed by another order, revoking his suspension and asking him to surrender his post.
Challenging the entire process, Judge Inalo Zhimomi filed a writ petition in the Gauhati High Court claiming violation of principles of natural justice and Supreme Court precedents.
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He also raised concerns about two orders passed during the writ petition proceedings, including one appointing an inquiry officer. Zhimomi questioned how such an inquiry could be initiated after his compulsory retirement was ordered.
Earlier, the Kohima bench of the Gauhati High Court had rejected his anticipatory bail plea on May 29, 2025.
Judge Inalo Zhimomi's counsel, Advocate Siddhartha Borgohain, cited the landmark case of K. Veeraswamy vs Union of India (1991) and questioned the validity of filing a criminal case against a judge without consulting the Chief Justice of India, as mandated under Section 154 of the CrPC.
Further, the petitioner claimed that while the FIR was provided to him, other crucial documents like the letter of the Principal District Judge and a copy of the bail register were not shared.
“Statutory procedures and natural justice have not been followed in the entire process,”— Petitioner before the Gauhati High Court
The Supreme Court, taking a balanced approach, has now granted interim protection by granting anticipatory bail while the High Court will continue to decide the matter.
Case Details: SHRI INALO ZHIMOMI v. THE STATE OF NAGALAND