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Murder Masked as Accident? P&H High Court Says No Bail When Hands That Held Enabled the Killing

Murder Masked as Accident? P&H High Court Says No Bail When Hands That Held Enabled the Killing

Case Name: Nand Lal @ Nandu v. State of Haryana

Date of Judgment: 20 March 2026

Citation: CRM-M-14364-2026

Bench: Hon’ble Ms. Justice Mandeep Pannu

Held: The High Court held that even a limited role such as holding the deceased during the act of strangulation constitutes active participation in a heinous offence, and in light of the gravity of allegations and stage of trial, the petitioner was not entitled to regular bail.

Summary: The present petition was filed seeking regular bail under Section 483 of the BNSS in FIR No. 303 dated 24.11.2024 registered under Section 103(1) of BNS (corresponding to Section 302 IPC) along with allied provisions, at Police Station Ding, District Sirsa.

As per the prosecution case, the deceased left home on a motorcycle and was later found admitted to a hospital with marks on his neck, raising suspicion of murder. It was alleged that the deceased was strangulated and his body was subsequently thrown on a highway to give the incident the appearance of an accident.

During investigation, the involvement of the petitioner and co-accused surfaced. The specific allegation against the petitioner was that he held the hands of the deceased while the co-accused strangulated him, followed by disposal of the body to mislead authorities.

The petitioner argued false implication, prolonged custody of over one year, and slow progress of trial, noting that only 2 out of 33 witnesses had been examined. However, the State opposed bail, highlighting the petitioner’s active role and the seriousness of the offence.

The Court observed that the role attributed to the petitioner, though limited, was crucial in facilitating the offence and could not be termed insignificant. The manner in which the crime was allegedly committed, followed by an attempt to disguise it as an accident, indicated premeditation. The Court further noted that the trial was at a nascent stage and release on bail could adversely affect the prosecution.

Decision: The High Court dismissed the petition for regular bail, holding that the gravity of the offence, the petitioner’s role, and the stage of trial did not justify grant of bail. It was clarified that observations made would not affect the merits of the case.

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