Punjab & Haryana HC Grants Bail in Murder Conspiracy Case, Notes Absence of Medical and Forensic Corroboration
Case Name: Manjit Singh @ Saini vs. State of Punjab
Date of Judgment: 01.09.2025
Citation: CRM-M No. 55685 of 2024.
Bench: Justice Manjari Nehru Kaul.
Held: The High Court granted bail to the petitioner accused of offences under Sections 302, 120-B and 34 IPC, noting that the prosecution’s case rested purely on circumstantial evidence without corroborative medical or forensic support. The Court found that the post-mortem and FSL reports contradicted the prosecution’s poisoning theory, as the cause of death was established as cardiorespiratory failure due to cardiomyopathy, and no poison was detected. Given that the petitioner had been in custody since 31.12.2023 and none of the 25 prosecution witnesses had been examined despite charges having been framed, further incarceration was held to be unjustified.
Summary: The FIR (No. 208 dated 05.12.2023) was registered at Police Station Kamboj, Amritsar, alleging that the petitioner, in connivance with co-accused Paramjit Kaur (second wife of deceased Bhag Singh), administered poison-laced juice leading to Bhag Singh’s death. The complainant, son of the deceased, claimed that Paramjit Kaur had an illicit relationship with the petitioner and had conspired to eliminate Bhag Singh to usurp property. It was further alleged that the petitioner was frequently present at the complainant’s home and had even been allowed to use part of the house as an office, strengthening the suspicion of conspiracy.
The petitioner argued that the prosecution’s case collapsed in light of medical and forensic evidence. The post-mortem attributed the cause of death to cardiorespiratory failure due to cardiomyopathy, and the FSL report categorically found no poison in the viscera. He further contended that he had been in custody since December 2023, that charges were framed in April 2025, but not a single prosecution witness had been examined thereafter. On these grounds, bail was sought.
The State and complainant opposed bail, reiterating the allegations of conspiracy and illicit relationship as motive. However, they were unable to dispute that no recovery had been made, no poison was detected, and the medical findings contradicted the FIR narrative.
Decision: The Court allowed the petition and ordered the release of the petitioner on bail, subject to furnishing of bonds to the satisfaction of the trial court. It clarified that the order should not be construed as an expression of opinion on the merits of the case, and reserved liberty to the State to seek cancellation of bail if the concession was misused. The Court emphasized that prolonged custody without corroborative evidence, and in the face of stalled trial proceedings, warranted conditional liberty over continued pre-trial incarceration.