‘Reasons Are Backbone of Judicial Decisions’: Supreme Court Sets Aside 3 Patna HC Bail Orders

The Supreme Court has said reasoning is the backbone of judicial decisions and is essential to ensuring the legality, propriety and correctness of orders, stressing that courts must provide their own independent analysis while deciding bail applications rather than merely recording the submissions of the parties.

A Bench of Justices Dipankar Datta and Sheel Nagu said an order granting or refusing bail must reflect an application of mind to the material available on record.

“Failure to consider crucial evidence, such as video footage and witness statements linking the accused to the crime, renders the bail order unsustainable and necessitates a fresh review,” Court said.

Court made the observation while setting aside three bail orders passed by the Patna High Court in a murder case, after finding that it had failed to consider video footage of the incident and witness statements identifying the accused. Court remitted the matters to the high court for fresh consideration.

The appeals were filed by Nagendra Ray, the father of Chandan Ram, who was allegedly shot dead during an incident in Bihar in May 2024. Ray challenged the high court’s orders granting anticipatory bail to Kamakhya Singh alias Deepu Singh and regular bail to Ram Pratap Singh alias Ravi Kant Singh and Ramakant Solanki alias Ramakant Singh.

The prosecution alleged that on May 20, 2024, during the Lok Sabha elections, some persons misbehaved with, abused and attempted to attack supporters of an RJD candidate without any provocation, following which an FIR was registered.

According to the prosecution, out of resentment, on May 21, 2024, at around 7 am, a large group of around 40-50 persons, including Kamakhya Singh, Ram Pratap Singh and Ramakant Solanki, armed with deadly weapons, surrounded the appellant’s son and others at Bhikhari Chowk.

Ramakant Solanki allegedly shot the appellant’s son in the chest, while Ram Pratap Singh allegedly shot Manoj Ram in the head. Two others in the group, Deepak Kumar and Guddu Kumar, were also shot at by other assailants.

Hearing the gunshots and screams, the appellant and others rushed to the spot, following which the accused allegedly fled while firing indiscriminately. The appellant’s son was declared dead at the hospital, while the others required medical treatment.

An FIR was registered at Town Police Station, Chhapra Nagar, District Saran, under Sections 147, 148, 149, 307, 302, 34 and 120B of the Indian Penal Code [corresponding to Sections 191(2), 191(3), 190, 109, 103(1), 3(5), and 61(2) of the Bharatiya Nyaya Sanhita (BNS)] and Section 27 of the Arms Act against the three accused and other co-accused.

A charge sheet was subsequently filed under Sections 147, 148, 149, 323, 307, 302 and 120B of the IPC and Sections 25(1-B)(a), 26, 27 and 35 of the Arms Act. A supplementary charge sheet was also filed against other co-accused persons, while the trial against the accused in the present case was pending.

On examining the orders granting relief to Kamakhya Singh and Ram Pratap Singh, the Supreme Court noted that the high court had completely omitted to consider the video footage, despite references to the footage in the sessions court's orders.

The Bench also noted that the high court had failed, in all the impugned orders, to consider the statements of witnesses recorded under Section 161 of the Code of Criminal Procedure, 1973, who had identified the relevant accused after being shown the video footage.

In the case of Ramakant Solanki, Court noted that although the high court had recorded the submission of the Investigating Officer regarding the video footage, it had failed to independently analyse whether the footage adversely affected Solanki's prayer for bail.

“Merely recording the submissions of the parties without any independent assessment of such submissions is not a proper approach while dealing with applications for bail. Reference to material, however concise they may be, ought to be made to show application of mind. Importantly, it is ‘the reasons’ which form the backbone of all judicial decisions,” the Bench said.

Court accordingly remitted the matters to the high court for fresh consideration of the respective applications for anticipatory bail and bail, noting the high court's non-consideration of the video footage obtained by the police and the statements of witnesses under Section 161 CrPC who had identified the relevant accused after being shown the footage.

After setting aside the impugned orders, Court clarified that Kamakhya Singh, Ram Pratap Singh and Ramakant Solanki would continue to remain on interim bail, subject to the terms and conditions imposed by the high court, until the roster bench of the high court finally disposes of their applications after hearing the accused, complainant and police.

The high court may, subject to its convenience, list the applications for hearing together, the Bench said.

The Court clarified that the observations made in the order would not be treated as findings on the merits of the case.

Case Title: Nagendra Ray Vs State of Bihar & Anr

Bench: Justices Dipankar Datta and Sheel Nagu 

Date of Judgment: October 16, 2026