Mere Long Custody No Ground for Bail in Murder Case: P&H High Court Rejects Bail Where Accused Facilitated Strangulation

Case Name: Sandeep Singh @ Sandeep Kumar @ Deep @ Deep Singh v. State of Punjab

Date of Judgment: 30 March 2026

Citation: CRM-M-6496-2026

Bench: Justice Manisha Batra

Held: The Punjab & Haryana High Court held that prolonged custody alone is not a sufficient ground for grant of bail in serious offences like murder. Where the accused is alleged to have facilitated the commission of the offence and forms part of a chain of circumstantial evidence, bail can be denied to protect the integrity of the trial.

Summary: The petitioner filed a second bail application in a case involving allegations of murder of his sister-in-law. As per the prosecution case, the complainant had spoken to the deceased shortly before the incident and heard voices of both the petitioner and co-accused during a quarrel. Subsequently, the victim was found dead, and it was alleged that the co-accused strangulated her while the petitioner held her.

During investigation, voice recordings of the conversation were seized and sent for forensic examination. The petitioner and co-accused surrendered and made disclosure statements admitting involvement. The prosecution case rested on circumstantial evidence, including call recordings and statements.

The petitioner argued that there were no visible signs of strangulation, no direct evidence, and that he had been in custody since January 2023 with minimal progress in trial (only 1 out of 27 witnesses examined). It was further contended that disclosure statements are inadmissible and no recovery was effected from him.

The Court, however, found that the petitioner was specifically named in the FIR and his presence at the scene was corroborated by the complainant’s version of hearing his voice during the incident. The role attributed to him was holding the victim while co-accused strangulated her indicated active facilitation of the crime.

The Court held that even though the case is based on circumstantial evidence, the chain of circumstances prima facie pointed towards involvement of the petitioner. It further observed that disclosure statements, though subject to evidentiary scrutiny at trial, cannot be ignored at the stage of bail.

Importantly, the Court emphasized that seriousness of the offence and the possibility of influencing witnesses or tampering with evidence outweigh the argument of prolonged custody. It reiterated settled principles that bail is discretionary and must consider nature of accusation, severity of punishment, and likelihood of prejudice to trial.

Decision: The High Court dismissed the bail petition, holding that no compelling ground was made out for grant of bail in light of the serious allegations, role of the petitioner in facilitating the offence, and potential risk to fair trial.