LEGAL ISSUE: Whether the High Court was justified in granting interim bail on medical grounds without considering all the medical reports on record.
CASE TYPE: Criminal Appeal
Case Name: State of U.P. vs. Gayatri Prasad Prajapati
Judgment Date: 15 October 2020
Date of the Judgment: 15 October 2020
Citation: (2020) INSC 714
Judges: Ashok Bhushan, J., R. Subhash Reddy, J., M.R. Shah, J.
Can an accused person be granted interim bail solely on medical grounds when the state is providing adequate medical care? The Supreme Court of India addressed this question in a criminal appeal filed by the State of Uttar Pradesh against an order of the Allahabad High Court. The High Court had granted interim bail to a former minister, Gayatri Prasad Prajapati, who was accused of rape and offences under the Protection of Children from Sexual Offences (POCSO) Act, on medical grounds. The Supreme Court, in this judgment, clarified that interim bail cannot be granted without considering all the medical reports on record and when the state is providing adequate medical care. The judgment was delivered by a three-judge bench comprising Justices Ashok Bhushan, R. Subhash Reddy, and M.R. Shah, with the opinion authored by Justice Ashok Bhushan.
Case Background
The respondent, Gayatri Prasad Prajapati, a former minister in the State of Uttar Pradesh, was accused in a case registered under Sections 376(D), 376, 511, 504, and 506 of the Indian Penal Code, 1860, along with Sections 3 and 4 of the POCSO Act. The case was registered following an order by the Supreme Court on 17 February 2017, in a writ petition filed by the complainant. Initially, the respondent was granted bail by the Additional District and Sessions Judge, Lucknow, on 25 April 2017. However, this bail was cancelled by the High Court on 26 May 2017, upon an application by the State of U.P., before the respondent could be released from jail.
Another bail application filed by the respondent was rejected by the High Court on 14 December 2017. The respondent was admitted to King George Medical University (K.G.M.U.), Lucknow, for treatment on 3 May 2019. He then filed a bail application and an application seeking interim bail on medical grounds. The respondent remained admitted in K.G.M.U. until 17 January 2020, when he was discharged. Subsequently, the High Court directed that the respondent be examined at the Department of Urology of K.G.M.U. under police supervision. A medical board was also constituted to evaluate the respondent’s condition.
On 9 March 2020, the respondent was again admitted to K.G.M.U. He was later shifted to Sanjay Gandhi Postgraduate Institute of Medical Sciences (S.G.P.G.I.M.S.), Lucknow, for specialized treatment on 4 June 2020. The medical board submitted its report on 10 June 2020. After being shifted back to K.G.M.U. on 29 June 2020, the High Court granted the respondent interim bail on medical grounds on 3 September 2020. Aggrieved by this order, the State of U.P. filed an appeal before the Supreme Court.
Timeline
| Date | Event |
|---|---|
| 17 February 2017 | Supreme Court orders registration of FIR against the respondent. |
| 25 April 2017 | Additional District and Sessions Judge, Lucknow grants bail to the respondent. |
| 26 May 2017 | High Court cancels the bail granted to the respondent. |
| 14 December 2017 | High Court rejects another bail application of the respondent. |
| 3 May 2019 | Respondent is admitted to K.G.M.U. for treatment. |
| 17 January 2020 | Respondent is discharged from K.G.M.U. |
| 5 March 2020 | High Court directs the respondent to be examined at the Department of Urology of K.G.M.U. |
| 9 March 2020 | Respondent is again admitted to K.G.M.U. |
| 4 June 2020 | Respondent is shifted to S.G.P.G.I.M.S. for specialized treatment. |
| 10 June 2020 | Medical board submits its report. |
| 29 June 2020 | Respondent is shifted back to K.G.M.U. |
| 3 September 2020 | High Court grants interim bail to the respondent on medical grounds. |
| 15 October 2020 | Supreme Court sets aside the order of the High Court granting interim bail. |
Course of Proceedings
The respondent, a former minister in Uttar Pradesh, was initially granted bail by the Additional District and Sessions Judge, Lucknow, which was later cancelled by the High Court. The High Court rejected another bail application before the respondent sought interim bail on medical grounds. The High Court, after considering the medical reports and the respondent’s condition, granted interim bail for two months. The State of Uttar Pradesh appealed this order to the Supreme Court, arguing that the High Court failed to consider all the relevant medical reports and that the state was providing adequate medical care.
Legal Framework
The case involves the interpretation of the principles governing the grant of bail, particularly interim bail on medical grounds, within the context of criminal proceedings. The Supreme Court considered the factual matrix of the case, focusing on whether the High Court properly assessed the medical condition of the respondent and the adequacy of the medical treatment provided by the state. The case also touches upon the rights of an accused person to humane treatment and medical care while in custody.
Arguments
Appellant (State of U.P.) Arguments:
- The respondent was receiving adequate medical treatment at K.G.M.U. and S.G.P.G.I.M.S., both reputable medical institutions.
- The High Court did not consider the medical board’s report, which was submitted following the High Court’s own order.
- The High Court relied on older medical opinions and the report of the Senior Superintendent of District Jail, rather than the most recent medical evaluations.
- The respondent’s medical condition was under control due to the treatment provided by the state.
- The interim bail condition that the respondent “shall ordinarily reside at a place of residence” indicates that the bail was not intended for medical treatment but for residing at home.
- The State was providing full medical facilities to the respondent, and there was no need for interim bail on medical grounds.
Respondent (Gayatri Prasad Prajapati) Arguments:
- Even if the offence alleged against the respondent is serious, he is entitled to humane treatment, especially when ill.
- The respondent was being moved from one hospital to another without his choice.
- The respondent’s medical condition required treatment at a tertiary care super-speciality hospital, which was not available at K.G.M.U.
- The respondent should be permitted to continue his treatment at K.G.M.U. and should not be transferred back to jail.
| Main Submission | Sub-Submissions by Appellant | Sub-Submissions by Respondent |
|---|---|---|
| Medical Treatment | ✓ Respondent received treatment at K.G.M.U. and S.G.P.G.I.M.S. ✓ Medical board report was not considered. ✓ State provided full medical facilities. ✓ Medical condition was under control. |
✓ Humane treatment is required when ill. ✓ Respondent was moved between hospitals without choice. ✓ Tertiary care was needed. |
| Interim Bail | ✓ Bail was not for medical treatment but for residence. ✓ No need for bail when state provides treatment. |
✓ Respondent should continue treatment at K.G.M.U. and not be transferred to jail. |
Issues Framed by the Supreme Court
The Supreme Court did not explicitly frame issues in a separate section but the core issue was:
- Whether the High Court was justified in granting interim bail on medical grounds without considering all the medical reports on record and when the state was providing adequate medical care.
Treatment of the Issue by the Court
| Issue | Court’s Decision | Reason |
|---|---|---|
| Whether the High Court was justified in granting interim bail on medical grounds? | Not justified. | The High Court failed to consider all medical reports, including the medical board’s report and treatment at S.G.P.G.I.M.S. The state was providing adequate medical care. |
Authorities
The Supreme Court did not cite any specific cases or books in its judgment. The court primarily relied on the facts of the case and the medical reports submitted by the hospitals.
| Authority | How the Court Considered the Authority |
|---|---|
| Medical reports from K.G.M.U. and S.G.P.G.I.M.S. | The Court noted that the High Court did not adequately consider these reports. |
| Report of the medical board | The Court observed that the High Court failed to refer to the report of the medical board, which was constituted on the direction of the High Court itself. |
Judgment
How each submission made by the Parties was treated by the Court?
| Submission | Court’s Treatment |
|---|---|
| Appellant’s submission that the respondent was receiving adequate medical treatment at K.G.M.U. and S.G.P.G.I.M.S. | Accepted. The Court agreed that the respondent was receiving treatment at reputable institutions and that the state was providing adequate medical care. |
| Appellant’s submission that the High Court did not consider the medical board’s report. | Accepted. The Court noted that the High Court failed to refer to or consider the medical board’s report. |
| Appellant’s submission that the High Court relied on older medical opinions and the report of the Senior Superintendent of District Jail. | Accepted. The Court observed that the High Court relied on older medical opinions and the report of the Senior Superintendent of District Jail, rather than the most recent medical evaluations. |
| Appellant’s submission that the respondent’s medical condition was under control due to the treatment provided by the state. | Accepted. The Court agreed that the respondent’s medical condition was under control due to the treatment provided by the state. |
| Appellant’s submission that the interim bail condition indicates that the bail was not intended for medical treatment. | Accepted. The Court noted that the interim bail condition that the respondent “shall ordinarily reside at a place of residence” indicates that the bail was not intended for medical treatment but for residing at home. |
| Appellant’s submission that the State was providing full medical facilities. | Accepted. The Court agreed that the State was providing full medical facilities and treatment to the respondent. |
| Respondent’s submission that even if the offence is serious, humane treatment is required when ill. | Acknowledged. The Court agreed that humane treatment is required for all, including those accused of serious crimes. |
| Respondent’s submission that the respondent was being moved from one hospital to another without his choice. | Noted. The Court acknowledged the respondent’s submission but did not find it sufficient to justify interim bail. |
| Respondent’s submission that the respondent’s medical condition required treatment at a tertiary care super-speciality hospital, which was not available at K.G.M.U. | Not Accepted. The Court noted that the respondent was being treated at S.G.P.G.I.M.S., a super-specialty hospital. |
| Respondent’s submission that the respondent should be permitted to continue his treatment at K.G.M.U. and should not be transferred back to jail. | Not Accepted. The Court did not accept the submission as a basis for interim bail. |
How each authority was viewed by the Court?
- The medical reports from K.G.M.U. and S.G.P.G.I.M.S. were considered crucial. The Court noted that the High Court did not adequately consider these reports while granting interim bail.
- The report of the medical board was also considered important. The Court observed that the High Court failed to refer to the report of the medical board, which was constituted on the direction of the High Court itself.
The Supreme Court allowed the appeal, setting aside the High Court’s order granting interim bail. The Court emphasized that the High Court did not adequately consider the medical reports from K.G.M.U. and S.G.P.G.I.M.S., including the medical board’s report. The Court highlighted that the respondent was receiving treatment at a super-speciality hospital, and there was no evidence that the medical care was inadequate. The Court noted that the High Court’s reasoning for granting interim bail was based on outdated information and did not reflect the respondent’s current medical condition or the treatment being provided.
The Court stated, “When the respondent was being given treatment in the super-speciality hospital, i.e., S.G.P.G.I.M.S. as recommended by K.G.M.U., we fail to see as to what were the shortcomings in the medical treatment offered to respondent, which could have been the basis for grant of interim bail on medical ground.”
The Court also observed, “There was no satisfaction recorded by the High Court that treatment offered to respondent was not adequate and he requires any further treatment by any particular medical institute for which it is necessary to release the respondent on interim bail on medical grounds.”
The Court further clarified, “Even as on date, due medical care is being taken of the respondent, which is apparent from the additional documents filed as Annexure A-2 and Annexure A-3 alongwith the application dated 10.10.2020.”
What weighed in the mind of the Court?
The Supreme Court’s decision was primarily influenced by the fact that the High Court had not properly considered all the medical reports on record, especially the report of the medical board and the treatment being provided at S.G.P.G.I.M.S. The Court emphasized that the respondent was receiving adequate medical care and that there was no justification for granting interim bail on medical grounds. The Court also noted that the High Court’s reasoning was based on outdated information and did not reflect the current medical situation. The Court was also influenced by the fact that the condition for the interim bail was that the respondent should ordinarily reside at a place of residence, which indicated that the bail was not for medical treatment.
| Sentiment | Percentage |
|---|---|
| Inadequate Consideration of Medical Reports | 40% |
| Adequacy of State Medical Care | 30% |
| High Court’s Reliance on Outdated Information | 20% |
| Interim Bail Condition | 10% |
Fact:Law Ratio
| Category | Percentage |
|---|---|
| Fact | 70% |
| Law | 30% |
Logical Reasoning:
High Court grants interim bail based on medical grounds
Supreme Court reviews medical records and finds that High Court did not consider all reports
Supreme Court notes that the state is providing adequate medical care
Supreme Court cancels interim bail
Key Takeaways
- Interim bail on medical grounds should not be granted if the state is providing adequate medical care.
- Courts must consider all relevant medical reports, including the most recent ones, before granting interim bail on medical grounds.
- The High Court should have considered the medical board’s report, which was submitted following the High Court’s own order.
- The condition for interim bail should be consistent with the purpose of the bail.
Directions
The Supreme Court did not issue any specific directions other than setting aside the order of the High Court. The Court clarified that its observations were only for deciding the appeal and would not affect the merits of the pending bail application before the High Court.
Development of Law
The ratio decidendi of the case is that interim bail on medical grounds should not be granted if the state is providing adequate medical care and the High Court must consider all relevant medical reports, including the most recent ones, before granting interim bail on medical grounds. This case clarifies that the High Court should not rely on outdated information and must consider the medical board’s report, especially if it was constituted on the High Court’s direction. This judgment reinforces the principle that the courts must ensure a balance between the rights of the accused and the interests of justice.
Conclusion
The Supreme Court’s decision in State of U.P. vs. Gayatri Prasad Prajapati underscores the importance of a thorough and comprehensive review of medical evidence before granting interim bail on medical grounds. The Court emphasized that when the state is providing adequate medical treatment, there is no justification for granting interim bail based on medical conditions. This judgment serves as a reminder to lower courts to consider all relevant medical reports and not to rely on outdated information while deciding on interim bail applications.