Lakshmanan v. State 2025 INSC 1483 - S.15A SC-ST Act - Bail -S.219 CrPC

Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act - Section 15A - Section 15A(5) incorporates the principle of audi alteram partem for victims under the SC/ST (POA) Act. Where such a right is conferred, the Court must provide the victim or their dependent an opportunity of audience, either personally or through counsel, including the Special Public Prosecutor. The statutory right to be heard presupposes that the victim is made aware of the proceedings and is not excluded therefrom- The provision guarantees an opportunity to be heard, not a right to a favourable outcome or to a detailed adjudication of every objection raised by the victim. Once the victim has been notified, permitted to participate, and allowed to place objections on record, the statutory mandate stands satisfied-Cancellation of bail on the ground of violation of Section 15A(5) is justified only in cases where no notice of the bail proceedings was served upon the victim, the victim was completely excluded from the proceedings, or the 20 victim was denied any opportunity of audience. In such circumstances, the violation strikes at the root of jurisdiction and renders the bail order legally unsustainable. However, bail cannot be cancelled merely because the court did not accept the victim’s submissions, the bail order does not specifically deal with or rebut each objection raised, or the victim alleges that the hearing was “mechanical” despite having been granted an opportunity - Courts, particularly at the stage of bail, are required only to form a prima facie view and bail orders are not expected to contain elaborate or exhaustive reasoning. Section 15A(5) does not mandate a detailed analysis or express rejection of every submission advanced by the victim. (Para 11)

Bail - Pendency of civil litigation neither dilutes criminal liability nor overrides considerations of gravity, antecedents, or witness safety. Reliance on the civil nature of the dispute, without addressing the serious criminal dimensions of the case, constitutes a misdirection in law. (Para 12.4)

Code of Criminal Procedure 1973- Section 219 [Section 242 BNSS] - Joinder of charges as an exception and not as the rule - separate trial is the norm, and joint trial is permissible only where the offences form part of the same transaction or where the statutory conditions under Sections 219 to 223 Cr.P.C (and corresponding BNSS provisions) are satisfied. This Court further held that even where statutory conditions permitting a joint trial are fulfilled, the conduct of a joint trial is a matter of judicial discretion and not compulsion. The decision must ordinarily be taken at the beginning of the trial, and must be guided by two paramount considerations, namely, whether a joint trial would cause prejudice to the accused and whether it would result in delay or wastage of judicial time. It was also emphasised that evidence recorded in one trial cannot be automatically imported into another and that procedural complications may arise if distinct trials are improperly clubbed. (Para 13)