Dataram Singh v. State of Uttar Pradesh
📌 Citation
(2018) 3 SCC 22
Decided on: 6 February 2018
Bench: Madan B. Lokur and Deepak Gupta
🔹 Background
The appellant sought bail after being denied relief by lower courts. The matter reached the Supreme Court, where the primary issue was whether bail should be granted when the accused has no criminal antecedents and the trial is likely to take time.
🔹 Core Issue
Whether denial of bail merely on seriousness of offence is justified, and what principles should guide courts while deciding bail applications.
🔹 Supreme Court Observations
The Court reiterated the fundamental principle:
“Bail is the rule and jail is the exception.”
Key Principles Laid Down:
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Presumption of Innocence
Every accused is presumed innocent until proven guilty. -
Personal Liberty under Article 21
Bail decisions must align with the constitutional guarantee of personal liberty. -
No Mechanical Denial
Bail cannot be rejected only because the offence is serious. -
Criminal Antecedents Matter
If the accused has no previous criminal record, that weighs in favour of bail. -
Socio-Economic Bias to be Avoided
Bail conditions should not be so harsh that poor accused persons cannot comply. -
Reasoned Orders Required
Courts must give brief but clear reasons while granting or rejecting bail.
🔹 Important Extract
The Court emphasized that detention pending trial should not be punitive, and prolonged incarceration without trial violates Article 21.
🔹 Legal Significance
This case strengthened the liberal bail jurisprudence flowing from:
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State of Rajasthan v. Balchand
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Gudikanti Narasimhulu v. Public Prosecutor
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Sanjay Chandra v. CBI
It reaffirmed that bail jurisprudence must balance individual liberty with societal interest.
🔹 Exam-Oriented Points (Judicial / APO / HJS)
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Article 21 directly linked to bail discretion.
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Socio-economic sensitivity in fixing surety amount.
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Courts must avoid “pre-trial punishment.”
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Criminal antecedents are a decisive factor.