Punjab & Haryana High Court Grants Bail in Circumstantial Evidence Murder Case After Two Years in Custody

Case Name: Parveen @ Dhila vs. State of Haryana
Date of Judgment: 14 November 2025
Citation: CRM-M-44734-2025
Bench: Hon’ble Mr. Justice Rajesh Bhardwaj

Held: The Punjab and Haryana High Court granted regular bail to the petitioner after observing that the prosecution case rested purely on circumstantial evidence and that the veracity of allegations could only be tested at trial. The Court noted that the petitioner had already undergone more than two years of incarceration, had no previous criminal antecedents, and that a substantial portion of prosecution witnesses had already been examined. Considering that the trial was likely to take considerable time to conclude, the Court found it appropriate to extend the benefit of bail. It clarified that nothing in the order should be treated as a comment on the merits of the case.

Summary: The case stemmed from FIR No. 107 dated 15 April 2023, where the complainant alleged that his brother Rohit was found dead with gunshot injuries at their residence after tensions arose between families following a suicide involving their relative. The petitioner, said to be the brother of the deceased’s brother-in-law, was suspected of committing the murder based on the motive that the complainant’s family had allegedly been blamed for the earlier suicide. According to the prosecution version, the petitioner and unknown accomplices were accused of entering the complainant’s home at night and shooting the victim. The petitioner was arrested based on a disclosure statement made by his father during investigation. The defence argued that the case was fabricated and built solely on circumstantial evidence without any credible material linking the petitioner to the occurrence, emphasizing delays in recording the “last seen” evidence and disputing the prosecution narrative. The petitioner further asserted that he was serving in the Army, was falsely implicated due to family rivalry, and that two co-accused were already granted bail.

Decision: After hearing arguments from all sides, the Court observed that although the allegations were serious, the prosecution case was entirely circumstantial and would require full appreciation during trial. The Court noted from the custody certificate that the petitioner had already undergone custody of two years, three months, and twenty-five days, and also recorded that he had no criminal antecedents. The Court also considered the progress of trial, noting that thirteen out of forty witnesses had already been examined. Holding that continued incarceration without trial conclusion would not serve the ends of justice, the petition was allowed and the petitioner was ordered to be released on regular bail subject to furnishing necessary bonds before the trial court. The Court concluded with a clarification that the observations were only for bail adjudication and would not affect the merits of the case.