The Supreme Court of India, in a ruling delivered by Justice Dipankar Datta and Justice Ahsanuddin Amanullah, has dismissed a review petition filed by Vitthal Damuji Meher, who sought reconsideration of the Court’s earlier decision cancelling his bail. The review petition was filed in Vitthal Damuji Meher v. Manik Madhukar Sarve & Ors. (Review Petition (Criminal) [Diary] No. 41376 of 2024), where the petitioner sought to overturn the Court’s August 28, 2024, judgment that set aside his bail granted by the High Court.
Background of the Case
Vitthal Damuji Meher, the petitioner, was arrested on April 28, 2021, and charged with serious offences, the details of which were outlined in the charge sheet filed shortly thereafter. The High Court of Maharashtra had granted him bail on October 13, 2021, after about five and a half months of incarceration. However, the Supreme Court, upon hearing the appeal (Manik Madhukar Sarve & Ors. v. Vitthal Damuji Meher & Ors., Criminal Appeal No. 3573 of 2024), cancelled this bail in a judgment dated August 28, 2024.
The petitioner, dissatisfied with the cancellation, filed a review petition arguing that the observations in the Court’s August judgment were erroneous. He contended that:
– The Court had misinterpreted the facts of the case, specifically Paragraph 26 of the judgment, which he believed contained factual inaccuracies.
– The principle of “bail is the rule, jail is the exception” had been ignored.
– He had been singled out while other co-accused had been released on bail.
Key Legal Issues and Arguments
1. Grounds for Bail Cancellation: The petitioner argued that the Supreme Court had failed to provide clear reasons for canceling his bail, especially when other co-accused were still out on bail. His counsel relied on the principle that “bail is the rule, jail is the exception” and contended that the petitioner should not have been treated differently without justification.
2. Precedents on Bail Cancellation: The petitioner pointed to earlier cases, including Union of India v. K.A. Najeeb (2021) and Sanjay Dubey v. State of Madhya Pradesh (2023), to argue that his incarceration for six months was substantial enough to warrant continued bail. He emphasized that the principle of equal treatment was violated as co-accused individuals had not faced similar restrictions.
3. Role of Judicial Discretion: The petitioner raised concerns about whether the trial and appellate courts, if tasked with considering future bail applications, would feel restricted by the earlier cancellation ordered by the Supreme Court.
Supreme Court’s Decision
The bench of Justices Dipankar Datta and Ahsanuddin Amanullah rejected the review petition, affirming their earlier judgment that cancelled the petitioner’s bail. They held that the petition failed to provide sufficient grounds for review under well-established jurisprudential principles. Citing precedents, the court emphasized that each case must be judged on its own facts and that the bail granted to co-accused does not automatically entitle another accused to similar relief.
The Court noted:
“Judgments are not to be read as Euclid’s theorems; they are not to be construed as statutes, and specific cases are authorities only for what they actually decide.”
In response to the petitioner’s claim of being singled out, the Court pointed out that his incarceration of five and a half months did not constitute a “significant period” under the legal standards for pre-trial detention as asserted by the petitioner. The Court further remarked that while the principle that “bail is the rule, jail is the exception” is valid, it does not mean that the accused is automatically entitled to bail in all circumstances, especially when charges are severe.
Observations on Future Bail Applications
In its August judgment, the Court had explicitly stated that the petitioner was free to apply for bail again “at a later period or in the event of a change in circumstances.” The petitioner, however, expressed concern that such a bail plea would be dismissed outright due to the prior cancellation of his bail by the Supreme Court. The Court dismissed this argument, clarifying that trial and appellate courts are fully empowered to independently evaluate any future bail application based on its merits, without being constrained by its earlier ruling.
The Court concluded:
“The discretion in this context, albeit, to be exercised in accordance with law, of the Court(s) below is left untouched.”
The Supreme Court, in dismissing the review petition, upheld its earlier decision to cancel Vitthal Damuji Meher’s bail, reiterating the importance of judicial discretion and individual case assessment in bail matters. The bench clarified that co-accused being on bail does not automatically translate into entitlement for the petitioner and that any future bail application should be judged on its merits. The Court’s ruling reaffirms the importance of judicial discretion while balancing personal liberty against the seriousness of criminal charges.
Case Details:
– Case Title: Vitthal Damuji Meher v. Manik Madhukar Sarve & Ors.
– Case Number: Review Petition (Criminal) [Diary] No. 41376 of 2024 in Criminal Appeal No. 3573 of 2024
– Bench: Justice Dipankar Datta and Justice Ahsanuddin Amanullah
– Counsels: The petitioner was represented by legal counsel, while the State and respondents were represented by their respective counsel.
