Court Emphasizes Seriousness of Custodial Death Allegations and Places Burden of Proof on Police Personnel to Rebut Charges; Application Barred Under Section 18 of SC/ST Act
In a significant ruling dated September 15, 2026, the Allahabad High Court, presided over by Justice Manish Mathur, dismissed the anticipatory bail application filed by Karan Singh Yadav, a personnel of the Railway Protection Force (RPF), accused in a custodial death case registered under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act). The case arose from the alleged custodial death of Sanjay Sonkar, brother of the informant, who reportedly died following brutal assault while in custody of the appellant and co-accused.
The incident occurred on November 4, 2025, when the appellant along with co-accused arrested and took Sanjay Sonkar for questioning related to an ongoing criminal investigation. Allegations state that after being taken into custody, Sanjay Sonkar was subjected to severe assault, resulting in his death the following day. The informant was informed on November 5, 2025, about the death and found the deceased's body at the mortuary.
The appellant contended that he was falsely implicated and pointed out that the post-mortem report indicated only minor injuries-contusions and abrasions-that could not have caused death. He asserted cooperation with the investigation and urged that there was no need for custodial detention.
However, the State opposed the bail application on the ground of the grave nature of allegations amounting to custodial death, an offence punishable with life imprisonment or death sentence under the SC/ST Act. The State also invoked the bar under Section 18 of the SC/ST Act, which generally prohibits anticipatory bail in such cases. The Court examined precedents, including the Supreme Court's judgments in Kiran v. Rajkumar Jivraj Jain (2025) and Prathvi Raj Chauhan v. Union of India (2020), noting that while anticipatory bail is generally barred, no definitive ruling had absolutely prohibited anticipatory bail applications in all SC/ST cases.
The Court observed that the FIR's allegations primarily concerned custodial death, a recurring and deeply troubling issue in law enforcement. It highlighted that the burden of proof rests heavily on police personnel to dispel such serious accusations, given the inherent vulnerability of individuals in custody. The Court noted that the evidence, including the post-mortem report, requires thorough trial examination but that prima facie, no sufficient grounds existed to grant anticipatory bail at this stage.
Consequently, the Allahabad High Court rejected the appellant's anticipatory bail plea, underlining the judiciary's stern approach towards custodial deaths and the protection of human rights, especially concerning Scheduled Castes and Scheduled Tribes.
This decision reinforces the judiciary's commitment to ensuring accountability of police personnel in custodial death cases and upholding the provisions of the SC/ST Act designed to prevent atrocities against marginalized communities.
Bottom Line:
Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 - Anticipatory bail application by police personnel accused of custodial death - Allegations of custodial death treated with utmost seriousness - Burden of proof lies upon police personnel to rebut allegations in such cases.
Statutory provision(s):
Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989: Sections 14A(2), 3(2)(v), 18; Bharatiya Nyaya Sanhita, 2023 Section 103(1) (as referenced)
Karan Singh Yadav v. State of U.P., (Allahabad) : Law Finder Doc Id # 2980647
