Introduction:
In the case of Sunny vs State of Uttar Pradesh (2026 LiveLaw (AB) 185), the Allahabad High Court, through a bench led by Justice Arun Kumar Singh Deshwal, delivered a significant ruling elucidating the limited scope and purpose of an inquest report under Section 194 of the Bharatiya Nagarik Suraksha Sanhita (BNSS). The case arose out of a bail application filed by the accused, Sunny, who was implicated in a murder case. The applicant sought bail primarily on the ground that his name did not appear in the inquest report, which instead mentioned an “unknown assailant.” The defense attempted to build a narrative that the absence of the accused’s name at the initial stage indicated false implication at a later point. However, the prosecution countered this claim with substantial evidence pointing towards the involvement of the accused, including eyewitness accounts, digital transaction records, and recovery of the weapon. The Court was thus confronted with a crucial legal question: whether the omission of the accused’s name in the inquest report undermines the prosecution’s case or entitles the accused to bail. In addressing this issue, the Court examined the statutory framework under Section 194 BNSS and drew upon established judicial precedents interpreting the corresponding provision under Section 174 of the Code of Criminal Procedure (CrPC). The judgment not only clarified the evidentiary value of an inquest report but also reinforced the principle that such reports are not meant to identify the perpetrator but merely to ascertain the apparent cause of death. Ultimately, the Court rejected the bail application, emphasizing the gravity of the offence and the strength of the evidence against the accused.
Arguments of the Applicant (Accused):
The applicant, Sunny, through his counsel, advanced a series of arguments aimed at discrediting the prosecution’s case and establishing his entitlement to bail. The central contention revolved around the alleged inconsistency in the initial stage of the investigation, particularly the contents of the inquest report and the early police records. It was argued that the case was initially registered as a “blind murder,” wherein the identity of the assailant was unknown. The inquest report, prepared in the presence of witnesses including the father of the first informant, explicitly mentioned that an “unknown person” had fired upon the deceased. The defense emphasized that if the father of the informant was present during the inquest proceedings and yet did not name the accused, it casts serious doubt on the subsequent implication of the applicant. The counsel further submitted that hospital records and the police diary at the initial stage also referred to the assailant as unknown, thereby reinforcing the claim that the applicant was not identified as the perpetrator at the earliest point of time. Building upon this, the defense argued that the subsequent naming of the applicant was an afterthought and a result of false implication. It was contended that the prosecution had failed to provide a satisfactory explanation for this discrepancy, which should weigh in favor of granting bail. The defense also sought to highlight the principle that bail is the rule and jail is the exception, particularly in cases where the evidence is not conclusive. By pointing to the absence of the applicant’s name in the inquest report, the counsel attempted to demonstrate that the prosecution’s case lacked reliability and consistency. Additionally, the defense argued that the inquest report, being an official document prepared at the earliest stage of investigation, holds significant evidentiary value and any omission therein cannot be lightly disregarded. The applicant thus urged the Court to consider these factors and grant bail, asserting that continued detention would be unjustified in light of the alleged weaknesses in the prosecution’s case.
Arguments of the Prosecution (State):
The State, opposing the bail application, presented a robust case to establish the involvement of the accused and to justify his continued custody. The prosecution categorically rejected the defense’s reliance on the inquest report, arguing that it was misplaced and legally untenable. It was submitted that the purpose of an inquest report is limited to ascertaining the apparent cause of death and documenting the nature of injuries, and not to identify or name the आरोपी (accused). Therefore, the absence of the accused’s name in the inquest report does not in any manner weaken the prosecution’s case. The State further relied on multiple pieces of evidence to demonstrate the prima facie involvement of the applicant. It was argued that several witnesses had seen the accused conducting “Reiki” (reconnaissance or surveillance) of the deceased prior to the incident, indicating premeditation and planning. This, according to the prosecution, established a clear motive and preparation on the part of the accused. Additionally, the prosecution highlighted digital evidence in the form of a UPI transaction made by the accused at a shop located near the crime scene just two hours before the incident. This placed the accused in close proximity to the location of the crime within a relevant timeframe. The State also emphasized the recovery of a .32 bore country-made pistol at the instance of the accused. This recovery was carried out in accordance with Section 105 BNSS and was duly supported by videographic evidence, thereby enhancing its credibility. The prosecution argued that this recovery constituted a crucial link in the chain of evidence against the accused. Furthermore, the State contended that the gravity of the offence—being a case of murder—necessitated a cautious approach in granting bail. It was argued that the role attributed to the accused was specific and substantiated by evidence, and that releasing him on bail could adversely affect the investigation and trial. The prosecution thus urged the Court to reject the bail application, asserting that the defense’s reliance on the inquest report was legally flawed and that the overall evidence strongly indicated the involvement of the accused.
Court’s Judgment:
The Allahabad High Court, after carefully evaluating the submissions of both parties and examining the relevant statutory provisions and precedents, rejected the bail application filed by the accused. The judgment delivered by Justice Arun Kumar Singh Deshwal provides a detailed exposition of the scope and purpose of an inquest report under Section 194 of the BNSS. At the outset, the Court addressed the primary contention raised by the defense regarding the absence of the accused’s name in the inquest report. The Court categorically held that there is no statutory requirement under Section 194 BNSS to mention the name of the accused in an inquest report. The provision merely mandates the investigating officer to prepare a report describing the apparent cause of death, including details of injuries such as wounds, fractures, and bruises, and to indicate the manner or weapon by which such injuries appear to have been inflicted. The Court emphasized that the inquest report is not a substantive piece of evidence and is limited in its evidentiary value. Its purpose is confined to forming a prima facie opinion regarding the cause of death, and it does not extend to identifying the perpetrator of the offence. To reinforce this interpretation, the Court relied on established precedents, including Amar Singh vs Balwinder Singh and others (2003) and Podda Narayana vs State of Andhra Pradesh (1975), wherein the Supreme Court had interpreted the corresponding provision under Section 174 CrPC. In these cases, it was clearly held that the inquest report is not required to mention the name of the accused and that its scope is limited to the apparent cause of death. The Court observed that these principles continue to apply under the BNSS, as Section 194 is substantially similar to Section 174 CrPC. Having clarified the legal position, the Court proceeded to examine the evidence against the accused. It noted that the prosecution had presented multiple pieces of evidence, including eyewitness accounts of the accused conducting reconnaissance of the deceased, digital evidence placing him near the crime scene, and the recovery of the weapon used in the offence. The Court found that these factors collectively established a prima facie case against the accused. The Court also took into account the gravity of the offence, observing that it was a serious case of murder involving a specific and active role attributed to the accused. In such circumstances, the Court held that the grant of bail would not be appropriate. The Court further observed that the defense’s attempt to rely solely on the inquest report to challenge the prosecution’s case was misplaced and did not create sufficient doubt to warrant bail. The Court concluded that the absence of the accused’s name in the inquest report does not invalidate the prosecution’s case or entitle the accused to bail. Accordingly, the bail application was rejected.