The Supreme Court of India has granted bail to an accused in a murder case, observing that the infringement of the right to a speedy trial as enshrined under Article 21 of the Constitution necessitates appropriate consideration for bail, regardless of the seriousness of the crime.
The bench comprising Justice J.B. Pardiwala and Justice Vijay Bishnoi passed the order on May 4, 2026, setting aside the denial of bail by the High Court of Judicature at Bombay (Circuit Bench at Kolhapur).
Background of the Case
The petitioner, Sahil Manoj Machare, was arrested on November 1, 2022, in connection with Crime No. 322/2022 registered with the Shahapur Police Station, District Kolhapur. He was charged with the offence of murder punishable under Section 302 read with Section 34 of the Indian Penal Code (IPC).
The petitioner had been in judicial custody for nearly four years. While the Trial Court had framed charges in 2024, the prosecution had failed to examine even a single witness since the inception of the case.
Arguments of the Parties
Mr. Risvi Muhammed, appearing for the petitioner, highlighted the prolonged incarceration of the accused and the lack of progress in the trial. On the other hand, Mr. Bharat Bagla, representing the State of Maharashtra, opposed the plea, presumably citing the gravity of the charges involving Section 302 of the IPC.
Court’s Analysis and Observations
The Supreme Court took serious note of the trial’s stagnation. The Court observed that despite the passage of significant time and the framing of charges two years prior, the trial had not progressed to the witness examination stage.
Regarding the constitutional right to a speedy trial, the Court stated:
“In such circumstances, referred to above, we are left with no other option but to say that the right of the accused to have speedy trial as enshrined under Article 21 of the Constitution could be said to have been infringed.”
Addressing the gravity of the alleged crime, the bench emphasized that the seriousness of an offence cannot override constitutional protections when trial delays become excessive. The Court remarked:
“We are mindful of the fact that the petitioner is charged with the offence of murder but time and again, we have said that howsoever serious the crime may be, if the right of speedy trial is infringed, then Court must consider the plea for bail appropriately.”
The Court specifically highlighted the four-year period of incarceration without any testimony being recorded as the primary factor for its decision.
The Decision
The Supreme Court allowed the Special Leave Petition and ordered the immediate release of the petitioner on bail. The release is subject to terms and conditions to be imposed by the Trial Court. The Court disposed of the petition and all pending applications with the directive that the petitioner be released forthwith if not required in any other case.
Case Details
- Case Title: Sahil Manoj Machare vs. The State of Maharashtra
- Case No.: Petition for Special Leave to Appeal (Crl.) No. 7502/2026
- Bench: Justice J.B. Pardiwala and Justice Vijay Bishnoi
- Date: May 4, 2026
