In a significant ruling on bail jurisprudence, the Supreme Court of India has granted bail to Md Imran alias D.C. Guddu, an accused summoned mid-trial in a murder case under Section 319 of the Code of Criminal Procedure (CrPC). The Court also refused to cancel the anticipatory bail granted earlier to two co-accused, bringing clarity on how courts should assess bail pleas of persons added later during trial.
The decision was delivered on January 7, 2026, by a Bench comprising Justice J.B. Pardiwala and Justice K.V. Viswanathan.
Background of the Case
The case traces back to a 2018 incident registered at Daily Market Police Station in Jharkhand. The FIR, lodged by the father of the deceased, named nine accused persons for offences including murder and rioting under the Indian Penal Code, along with violations of the Arms Act.
After investigation, the police filed a chargesheet against only three accused, submitting a closure report for the remaining six. However, during trial, family members of the deceased-who appeared as eyewitnesses-testified that all nine individuals were involved.
Based on this testimony, the complainant moved an application under Section 319 CrPC in 2022, seeking to summon the six dropped accused. The trial court partly allowed the plea and summoned three of them, including Md Imran @ D.C. Guddu. This order was never challenged and attained finality.
Md Imran was arrested after a non-bailable warrant and remained in judicial custody after the Jharkhand High Court rejected his bail plea. Meanwhile, the other two summoned accused approached the High Court before arrest and were granted anticipatory bail.
This led to two separate appeals before the Supreme Court-one by Md Imran seeking bail, and the other by the State of Jharkhand challenging the anticipatory bail granted to the co-accused.
Court’s Observations
After examining the eyewitness depositions and the procedural history, the Bench explained the legal standard applicable to bail applications of persons added under Section 319 CrPC.
The Court observed that when such an accused seeks bail, the judge must look for “strong and cogent evidence, and not mere probability of involvement.”
“The test is higher than a simple prima facie view taken at the stage of framing charges, but short of recording satisfaction that conviction is inevitable,” the Bench noted.
The judges emphasized that courts must carefully assess the nature of the offence, the quality of evidence, and the risk of the accused absconding or interfering with the trial.
The Supreme Court also took note of the fact that the two co-accused summoned under the same Section 319 order had already been enjoying anticipatory bail since July 2025 and were regularly appearing before the trial court.
Given this parity, the Bench found no justification to keep Md Imran incarcerated when the trial against all three had to proceed afresh and charges had already been framed.
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The Final Decision
Allowing Md Imran’s appeal, the Supreme Court directed that he be released on bail, subject to conditions imposed by the trial court.
At the same time, the Court dismissed the State’s appeal, holding that no case was made out for cancelling the anticipatory bail of the other two accused.
“The observations made herein are confined only to the question of bail,” the Bench clarified, adding that the trial court shall decide the case independently, uninfluenced by these findings.
All three accused have been directed to appear regularly before the trial court and cooperate for speedy disposal of the case.
Case Title: Md Imran @ D.C. Guddu vs State of Jharkhand
Case No.: Criminal Appeal arising out of SLP (Crl) No. 12110/2025
Decision Date: January 7, 2026
