Contract Killing Allegation & Conspiracy Role Weigh Heavy: Punjab & Haryana High Court Refuses Bail in SC/ST Act Murder Case
Case Name: Gori Singh v. State of Haryana and Another
Date of Judgment: 13 February 2026
Citation: CRA-S-1812-2025
Bench: Hon’ble Mrs. Justice Manisha Batra
Held: The Punjab and Haryana High Court held that in a case involving allegations of pre-planned murder pursuant to criminal conspiracy, where the accused is attributed a significant role in facilitating the contract killing, regular bail cannot be granted merely on grounds of parity, absence of recovery, or pendency of forensic reports. The Court held that at the stage of bail, disclosure statements and prima facie material indicating conspiracy are sufficient to deny relief.
Summary: The present appeal under Section 14-A(2) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 was filed challenging the order dated 25.02.2025 passed by the Additional Sessions Judge, Fatehabad, dismissing the appellant’s application for regular bail under Section 439 Cr.P.C.
The case arose from FIR No. 34 dated 15.02.2024 registered under Sections 302, 201, 34 and 120-B IPC and Section 3(2)(va) of the SC/ST Act at Police Station City Ratia, District Fatehabad.
The victim, Gosha Kaur, a nurse working in Tohana, had gone missing on 04.02.2024. Her body was later recovered from the Ghaggar River and cremated after inquest proceedings as unidentified. On 10.07.2024, her father identified her from photographs and alleged that one Ramphal @ Rafi, who had been pressurising her for marriage, had murdered her.
During investigation, the main accused Ramphal made a disclosure statement alleging that he had entered into a criminal conspiracy with the present appellant in December 2023. As per the prosecution, the appellant introduced Ramphal to a contract killer, Jagdish @ Khan, who agreed to commit the murder for ₹2.5 lakhs. The victim was allegedly strangulated with a muffler and charging wire, and her body disposed of in the river. The appellant was arrested on 14.02.2024 and also made a disclosure statement.
The appellant contended that he was not named in the FIR, was implicated solely on disclosure statements, no recovery was effected from him, DNA report was awaited, and co-accused had been granted bail. He also argued that he belongs to the SC/ST community and therefore provisions of the SC/ST Act were not attracted. He had been in custody since 14.07.2024 and investigation was complete.
The State opposed the appeal, submitting that the appellant played a key role in facilitating the conspiracy by introducing the contract killer and that the offence was grave and premeditated.
The High Court observed that the allegations were not peripheral. The role attributed to the appellant was qualitatively distinct and significant, as he allegedly facilitated the execution of the crime. The Court held that at the stage of bail, detailed appreciation of evidence is impermissible and disclosure statements can be considered for prima facie assessment.
The plea of parity was rejected on the ground that co-accused who were granted bail were only alleged to have supplied the sack used for disposal of the body, whereas the appellant’s role was central to the conspiracy.
Considering the seriousness of the offence, the manner of commission, and apprehension of witness intimidation, the Court found no ground to interfere with the trial Court’s order.
Decision: The appeal was dismissed. The order dated 25.02.2025 refusing regular bail was upheld.