Paragraph numbers below are the court’s original numbering, recovered from the source text.
30. Since the High Court has touched Section 30 of the Evidence Act, we would like to say something in this regard. The said provision reads thus: – 1234 “When more persons than one are being tried jointly for the same offence, and a confession made by one of such persons affecting himself and some other of such persons is proved, the court may take into consideration such confession as against such other person as well as against the person who makes such confession.”
31. As per Section 5 of Evidence Act, only those facts or facts in issue which are considered relevant under Chapter II of the Act would be admissible as evidence. Section(s) 24 to 30 of the Evidence Act, deals with the relevancy and admissibility of ‘confessions’ as evidence. Section 24 of the Evidence Act provides when a confession would be relevant by laying down a negative rule of relevancy and prescribing the general parameters when a confession would be considered irrelevant; namely when such confession is caused by either threat, inducement or promise.
32. Section(s) 28 and 29 of the Evidence Act respectively are an exception to the aforesaid general rule of relevancy of confessions. Section 28 provides that where although any threat, inducement or promise was made to cause a confession, yet if such confession was made after the cessation, removal or eradication of such improper influence or impression, then such confession would be relevant. Section 29 on the other hand, expands the test of relevancy by prescribing a positive rule of when a confession would continue to be relevant and provides that a confession made under one particular type of promise i.e., a promise of secrecy or made as a result of any deception, intoxication or by one’s own volition in response to any question, would not render such confession irrelevant.
33. Section 25 of the Evidence Act, goes one step further, by providing that even if such confession is not hit by Section 24 i.e., it is not the result of any threat, inducement or promise and thus, considered relevant, still such confession would be inadmissible if it was made to a police officer. Section 26 and 27 of the Evidence Act, however, carves out an exception to this. Section 26 provides that, a confession made by the accused to persons other than police officers would be inadmissible, if it was made whilst he was in police custody, unless such confession was made in the presence of a magistrate. Whereas, Section 27 only permits limited use of such statement only to the [2025] 5 S.C.R. P Krishna Mohan Reddy v. The State of Andhra Pradesh extent that a fact is discovered pursuant to disclosure statement which would connect the accused with the crime with authorship of concealment.
34. Section 30 of the Evidence Act, provides that a confession made by a person admitting his own guilt and at the same time implicating another person, such confession “may be taken into consideration” by the court against the maker as-well as against the person it is being made, if both of them are being “tried jointly”.
35. The Privy Council in Bhuboni Sahu v. R reported in 1949 SCC OnLine PC 12 explained the significance of the expression “may take into consideration” used in Section 30. It observed that a “confession” does not come within the definition of “Evidence” under Section 3 of the Evidence Act, as it is neither required to be given on oath, nor in the presence of the co-accused, and the same cannot be tested by cross-examination. Thus, although a confession against a co-accused, is not an evidence, yet as per Section 30, a court may take it into consideration and act upon it. However, the courts must be mindful that such confessions do not amount to proof, it is only one of the elements in the consideration of all other facts proved in a particular case, and therefore, there must be other evidence before such confession is taken into consideration. [See also: K. Hashim v. State of T.N., (2005) 1 SCC 237; State (NCT of Delhi) v. Navjot Sandhu, (2005) 11 SCC 600]
36. This Court in Kashmira Singh v. State of M.P reported in (1952) 1 SCC 275 further explained as to when such confession may be taken into consideration against another co-accused. Placing reliance on the decision of Periyaswami Moopan, In re. reported in 1930 SCC OnLine Mad 86 it was held that, “where there is evidence against the co-accused sufficient, if believed, to support his conviction, then the kind of confession described in Section 30 may be thrown into the scale as an additional reason for believing that evidence” and “the proper way is, first, to marshal the evidence against the accused excluding the confession altogether from consideration and see whether, if it is believed a conviction could safely be based on it. If it is capable of belief independently of the confession, then of course it is not necessary to call the confession in aid. But cases may arise where the Judge is not prepared to act on the other evidence as it stands even though, if believed, it would be sufficient to sustain a 1236 conviction. In such an event the Judge may call in aid the confession and use it to lend assurance to the other evidence and thus fortify himself in believing what without the aid of the confession he would not be prepared to accept”. Thus, such a confession can only be pressed into consideration by the court as a rule of prudence, to lend assurance to the other evidence against such co-accused.
37. The ingredients or conditions required under Section 30 of the Evidence Act, before any confession is made to operate against a co-accused are as under: – (i) there must be joint trial for the same offence; (ii) it must be a confession; (iii) the confession must inculpate or implicate the maker and to the same extent the other accused (iv) the confession of guilt must be duly proved. The aforesaid four conditions have to be strictly established. Such confession cannot be taken into consideration under Section 30 where the confession itself was not relevant or inadmissible or where a co-accused was not being tried jointly with the accused person who made the confession or where he did not make a statement incriminating himself along with the co-accused. [See Mohd. Khalid v. State of W.B., (2002) 7 SCC 334; Govt. of NCT of Delhi v. Navjot Sandhu, (2003) 10 SCC 586]
38. In Suresh Budharmal Kalani v. State of Maharashtra reported in (1998) 7 SCC 337, this Court held that under Section 30 of the Evidence Act a confession of an accused is relevant and admissible against a co-accused if both are jointly facing trial for the same offence. However, such confessional statements of an accused cannot be used against a co-accused in terms of Section 30 of Evidence Act, for the purpose of framing charges in the absence of any other evidence to do so. Similarly, where one of the accused has been discharged, confessional statement of such accused persons cannot be used against a co-accused, as the pre-condition under Section 30 of the Evidence Act, namely of there being a joint trial for the same offence is not fulfilled.
39. The High Court has its own understanding of Section 30 of the Evidence Act. It says that what is admissible under Section 30 can [2025] 5 S.C.R. P Krishna Mohan Reddy v. The State of Andhra Pradesh also be looked into at the stage of considering the plea of anticipatory bail or even regular bail. However, we are not impressed with the view expressed by the High Court. We are of the considered opinion that such a confession if any cannot be looked into at the stage of anticipatory bail or even regular bail for the following reasons: – (i) Before a confession is taken into consideration against a co- accused, the said confession has to be duly proved against the maker. It has to be clearly established that such confession is not vitiated either by Section 24 of the Evidence Act nor rendered inadmissible by Section 25 thereof, which can only be ascertained in the course of trial. It must be clearly established by leading cogent evidence in the course of the trial before the case for the prosecution comes to an end. [See: Dipak Bhai Jagdishchandra Patel v. State of Gujarat & Anr., (2019) 16 SCC 547]. When confession is made before police official, the same cannot be proved in evidence at all. Statement contemplated under section 30 should be relevant and admissible, and that is the foremost requirement of section and sine qua non. (ii) Section 30 of Evidence Act postulates that such a confession can be taken into consideration only where the accused persons are jointly tried. The said provision does not merely require that the persons must be accused of the same offence, but rather requires that they must be being tried jointly for the said offence. [See: Queen Empress v. Jagat Chandra Mali, ILR (1894) 22 Cal 50; Naresh v. R, AIR 1938 Cal 479]. Joint trial here refers to the one provided under Section 223 of the Code of Criminal Procedure, 1973 (for short, the “Cr.P.C.”). Thus, where the accused persons are either not being tried jointly, or are yet to be charged for the same offence and thereafter tried together, Section 30 of the Evidence Act would be inapplicable. [See: Badri Prasad Prajapati v. State of M.P., (2005) Cr.L.J. 1856]. Thus, Section 30 of the Evidence Act, would not spring into action when the charges are yet to be framed and the accused persons are yet to be committed to trial, and any confession admissible thereunder cannot be taken into consideration by the courts. (iii) Assuming for a moment that such a confession can be looked into at the stage of anticipatory bail or even regular bail, as 1238 per Kashmira Singh (supra), such a confession can only be pressed into consideration by the court as a rule of prudence, to lend assurance to the other evidence against such co-accused. Thus, there must exist other evidence on record, before the court looks into such confession.
40. Where a confessional statement is otherwise excluded or inadmissible by virtue of Section(s) 25 or 26 of the Evidence Act, respectively, there can be no question of such confessional statements being made admissible against another co-accused by stretching it with the help of Section 30 of the Evidence Act. Section 25 places a complete ban on the making of such confession by that person whether he is in custody or not. Section 26 lays down that a confession made by a person while he is in the custody of a police officer shall not be proved against him unless it is made in the immediate presence of a Magistrate. [See: Sahib Singh v. State of Haryana, (1997) 7 SCC 231] Confessional statement contemplated under Section 30 of the Evidence Act, must be both relevant and admissible in terms of the Evidence Act.
41. At this stage, we may clarify, with a view to obviate any possibility of confusion, whether a confession statement of an accused person implicating another co-accused be taken into consideration against such co-accused in terms of Section 161 of the Cr.P.C.
42. It is no more res integra that a person who is accused of an offence or named in the first information report, can be examined by the police and his statement may be recorded under Section 161 of the Cr.P.C., in this regard reliance may be placed on the decision of this Court in Nandini Satpathy v. P.L. Dani & Anr. reported in AIR 1978 SC 1025. However, the question as to whether such statement of the accused is admissible in law and in what manner can the same be looked into was explained by this Court in Mahabir Mandal & Ors. v. State of Bihar reported in AIR 1972 1331, wherein it was held that as per Section 162 of the Cr.P.C. no statement made by any person to a police officer in the course of an investigation shall be signed by the person making it or used for any purpose at any enquiry or trial in respect of any offence under investigation at the time when such statement was made. The only instance where such statements may be considered or looked into has been provided in the Proviso to sub-section (1) [2025] 5 S.C.R. P Krishna Mohan Reddy v. The State of Andhra Pradesh of Section 162, which permits the use of such statement or any part thereof, to contradict such witness in the manner provided by Section 145 of Evidence Act or in the re-examination of such witness for the purpose only of explaining any matter referred to in his cross-examination.
43. A statement given by an accused to the police under Section 161 of the Cr.P.C. may be either in the form of a confession or an admission. The Privy Council in Pakala Narayana Swami v. Emperor reported in (1939) PC 47 explained that a confession is a statement admitting the offence or at any rate substantially all the facts which constitute the offence, whereas an admission is only in respect of a gravely incriminating fact. Even a conclusively incriminating fact is not of itself a confession. Where such statement is a confessional statement, the rigour of Section(s) 25 and 26 will apply in full force, and the said confession would be completely inadmissible as held in Sahib Singh (supra) and a catena of other decisions of this Court. Where, however, such statement amounts to an admission, the statement being one under Section 161, would immediately attract the bar under Section 162 of the Cr.PC., and the same may be used only for the very limited purpose provided in the Proviso as held in Mahabir Mandal (supra).
44. We are conscious of a handful of decisions of this Court wherein it has been held that statements under Section 161 of the Cr.P.C. ought to be looked into by the courts in deciding the question of grant of bail. Indresh Kumar v. State of Uttar Pradesh & Anr., reported in 2022 SCC OnLine SC 2411 observed that “statements under Section 161 of Cr. P.C. may not be admissible in evidence, but are relevant in considering the prima facie case against an accused in an application for grant of bail in case of grave offence”. Similarly, in Salim Khan v. Sanjai Singh reported in (2002) 9 SCC 670, it was held that the court is “duty-bound to consider all the statements recorded under Section 161 CrPC, examine the gravity of the offence and also examine the question of possibility of the accused tampering with the evidence and possibility of getting the attendance of the accused during trial and then would be entitled to grant bail to an accused”.
45. However, the aforesaid observations cannot be singled out and construed devoid of its context. While it is permissible for the courts 1240 to examine the statements recorded under Section 161 of the Cr.P.C. for the purpose of ascertaining whether a prima-facie case has been made out against the accused and the nature or gravity of the allegations, the same applies only insofar as such police statements are of witnesses and not accused persons.
46. Both Indresh Kumar (supra) and Salim Khan (supra) have held that in deciding the question of grant of bail, it is the statements of witness under Section 161 of the Cr.P.C. that has to be looked into. Nowhere has this Court held that even the police statements of the accused person under Section 161 of the Cr.P.C. must also be looked into at the stage of grant of anticipatory or regular bail.
47. This is because a statement of an accused under Section 161 of the Cr.P.C stands on a different footing from a police statement of any ordinary witness. Statements of an accused person under Section 161 of the Cr.P.C. by virtue of ordinarily being in the form of either an admission or a confession cannot be looked into qua another co-accused, as to say otherwise would be to ignore the substantive provisions of Section(s) 17, 21, 25 and 26 of the Evidence Act and the well settled cannons of law of evidence. However, the aforesaid does not apply, where the statement of an accused under Section 161 of the Cr.P.C is exculpatory in nature, which we shall discuss later.
48. As per Section(s) 17 read with 21 of the Evidence Act, the general principle is that an admission may be given as evidence against the maker only and cannot be used against any other person. The only two exceptions to the aforesaid rule are in the context of civil disputes, i.e., where a party having a joint interest with others makes an admission relating to a subject-matter, it can be used against others or where such admission is sought to be used against any heir or persons claiming interest through or under the makers of such admission.
49. As explained in Pakala Narayana Swami (supra), a confession is one specie of an admission, this flows from the logic that every confession is an admission but not every admission is a confession, while admissions in itself is a specie or type of a statement. As a natural corollary to the aforesaid, any statement of the accused under Section 161 of the Cr.P.C. which is in the form of an admission that admits any incriminating fact or implicates another person by [2025] 5 S.C.R. P Krishna Mohan Reddy v. The State of Andhra Pradesh such statement, would be governed by the provisions of Section 17 of Evidence Act, more particularly the prohibition of usage of such admissions against third-persons. An admission by one accused cannot be used against another co-accused. [See: Chintamani Das v. State, AIR 1970 Ori 100; Sohar Singh v. State of Bihar, AIR 1960 Pat 448]. The aforesaid may be looked at from one another angle, since the Evidence Act, more particularly, Section(s) 17 and 30 clearly stipulate in well-defined terms, when an admission or a confession, respectively, may be used against another person, the logical sequitur of the aforesaid is that, except for the manner laid down under the said provisions, no admission or confession may be used against another person. Since, Section 17 of the Evidence Act does not postulate the use of an admission by one accused against another, any statement of the accused under Section 161 of the Cr.P.C., implicating such co-accused cannot be looked into by the courts.
50. Even where the police statement of an accused person under Section 161 of the Cr.P.C is neither an admission nor a confession, i.e., it is exculpatory in nature and not inculpatory, such statements can be looked into by the courts only for the limited purpose of culling out the stance of the accused person qua the allegations. An exculpatory police statement of an accused person under Section 161 of the Cr.P.C which at the same time implicates another co-accused, cannot be relied upon, merely because such statement is not hit by the safeguards and rigours that apply in respect of inculpatory statements in the form of an admissions or confessions under the Evidence Act. The fundamental cannon of criminal jurisprudence is that a statement of one accused person cannot be used against another co-accused person. The limited exception to this aforesaid general principle are inculpatory confessions, where the accused person in his confessional statement not only admits his own guilt but also implicates another co-accused. The rationale behind this limited exception as explained in Bhuboni Sahu (supra), is that an admission by an accused person of his own guilt affords some sort of credibility or sanction in support of the truth of his confession against others as-well as himself. An exculpatory statement is an affront to the aforesaid principle. Thus, an exculpatory statement of an accused person under Section 161 of the Cr.P.C. can only be looked into for the limited purpose of either culling out the stance 1242 of the accused person qua the allegations or for contradicting the accused, if the accused chooses to be examined as a witness in terms of Section 315 of the Cr.P.C. However, such exculpatory statement insofar as it implicates another co-accused person can in no manner be relied upon by the courts as against such co-accused as such statements by their nature cannot be tested by cross-examination if such accused person declines to be a witness in the trial in terms of Section 315 of the Cr.P.C., and because such exculpatory statement has no credibility.
51. Such statements at best could be said to be helpful to the investigating authorities for the purpose of ascertaining that the investigation is proceeding in the right direction or not, as ordinarily, once the investigation is over, these statements are neither supplied to the accused along with chargesheet nor placed on record.
52. Thus, Section 30 itself makes it clear that the whole legal exercise by virtue of which this provision of law can be made applicable, depends upon the proving of confession before a court which makes it into an admissible one in order to implicate the other accused provided the confession given by such person is established with full strength on the basis of other materials pertaining to the attendant circumstances. It would necessarily mean that mere confession alone will not be adequate or sufficient to implicate other persons. It is incumbent that there are other materials also which would render support or substantiate the case of the confession. However, it is subject to the standard of proving as contemplated by law. If this is the position, the court should look into the statements alleged to have been given by the co-accused and that too before a police officer during the course of investigation with great care and circumspection. The said statements are directly hit by Section 161 of the Code of Criminal Procedure. Particularly, the statement given by any one of the accused persons and recorded by the police officer during the course of investigation cannot be relied upon by the prosecution, except subject to the limitations provided by Section 145 of the Indian Evidence Act. The statement given by an accused involving himself in the crime and also implicating third person cannot be proved legally in the court. It will be in direct conflict with Sections 25 and 26 respectively of the Evidence Act. If such evidence or confession cannot be proved, then the occasion for utilizing such statement against another person would not arise. [2025] 5 S.C.R. P Krishna Mohan Reddy v. The State of Andhra Pradesh
53. From the above exposition of law, the following emerges: – (i) A person who is accused of an offence or named in the first information report, can be examined by the police and his statement may be recorded under Section 161 of the Cr.P.C., as held in Nandini Satpathy (supra). (ii) A statement of an accused under Section 161 of the Cr.P.C, would ordinarily be of two kinds, it may be inculpatory in nature or may be exculpatory in nature. (iii) An inculpatory statement again may be in the form of an admission or a confession. If such statement admits either a gravely incriminating fact or substantially all the facts which constitute the offence, respectively, as held in Pakala Narayana Swami (supra), then it amounts to confession. (iv) Where such police statement of an accused is confessional statement, the rigour of Section(s) 25 and 26 respectively will apply with all its vigour. A confessional statement of an accused will only be admissible if it is not hit by Section(s) 24 or 25 respectively and is in tune with the provisions of Section(s) 26, 28 and 29 of the Evidence Act respectively. In other words, a police statement of an accused which is in the form of a confession is per se inadmissible and no reliance whatsoever can be placed on such statements either at the stage of bail or during trial. Since such confessional statements are rendered inadmissible by virtue of Section 25 of the Evidence Act, the provision of Section 30 would be of no avail, and no reliance can be placed on such confessional statement of an accused to implicate another co-accused. (v) A confessional statement of one accused implicating another co-accused may be taken into consideration by the court against such co-accused in terms of Section 30 of the Evidence Act, only at the stage of trial, where (1) the confession itself was relevant and admissible in terms of the Evidence Act; (2) was duly proved against the maker; (3) such confessional statement incriminates the maker along with the co-accused and; (4) both the accused persons in question are in a joint trial for the same offence. (vi) Furthermore, because such confessional statements are not “evidence” in terms of Section 3 of the Evidence Act as held in 1244 Bhuboni Sahu (supra), such a confession as held in Kashmira Singh (supra) can only be pressed into consideration by the court as a rule of prudence, to lend assurance to the other evidence against such co-accused, provided that aforesaid ingredients or conditions of Section 30 read with Section(s) 24 to 29 of the Evidence Act, are fulfilled. (vii) Where the police statement of an accused is in the form of an admission, such inculpatory statement even if it implicates another co-accused cannot be taken into consideration against such co-accused in terms of Section(s) 17 read with 21 of the Evidence Act, as doing so would militate against the general principle, that an admission may be given as evidence against the maker alone. The exceptions to the aforesaid general principle carved out under the Evidence Act, do not permit the usage of such admission against a co-accused in any scenario whatsoever. (viii) Where the police statement of the accused is an exculpatory statement i.e., it is neither a confession nor an admission, the statement being one under Section 161, would immediately attract the bar under Section 162 of the Cr.PC., and the same may be used only for the very limited purpose provided in the Proviso for the purpose of contradiction or re-examination of such accused person alone, as held in Mahabir Mandal (supra). Even if such exculpatory statement of one accused, implicates another co-accused, the same cannot be taken into consideration against such co-accused, as there can be no credibility attached to an exculpatory statement of an accused implicating another co-accused, more particularly because it is neither required to be given on oath, nor in the presence of the co-accused, the same cannot be tested by cross-examination and the exculpatory nature of such statement militates against the foundational principle that permits taking into consideration a statement of one accused person against another co-accused as explained in Bhuboni Sahu (supra), i.e., ‘when a person admits guilt to its fullest extent either to a certain incriminating fact or substantially all the facts which constitute the offence, and in doing so exposes himself and in the process other co-accused persons to the pain and penalties provided for the [2025] 5 S.C.R. P Krishna Mohan Reddy v. The State of Andhra Pradesh guilt, there exists a sincerity and semblance of sanction for the truthfulness of such statement’. (ix) Although a handful of decisions of this Court such as Indresh Kumar (supra) and Salim Khan (supra) have held that statements under Section 161 of the Cr.P.C. ought to be looked into by the courts at the stage of anticipatory or regular bail for the purpose of ascertaining whether a prima-facie case has been made out against the accused and the nature and gravity of the allegations, yet the aforesaid rule only applies insofar as such statements under Section 161 were made by witnesses and not accused persons. A statement of an accused under Section 161 of the Cr.P.C. stands on a completely different footing from a police statement of a witness. As already discussed in the foregoing paragraphs, if the police statement of an accused is inculpatory in nature, its more in the form of a confession or admission rather than a statement, and the relevant provisions of Section(s) 17 to 30 of the Evidence Act, will apply with all its vigour. Where such statement of the accused is exculpatory in nature, the same can be looked into by the courts only for the limited purpose of either culling out the stance of the accused person qua the allegations or for contradicting the accused, if the accused chooses to be examined as a witness in terms of Section 315 of the Cr.P.C.. However, such exculpatory statement insofar as it implicates another accused person cannot be looked into by the courts, as such statements by their nature cannot be tested by cross-examination if such accused person declines to be a witness in the trial in terms of Section 315 of the Cr.P.C., and because such exculpatory statement has no credibility as explained in Bhuboni Sahu (supra). (x) Before the court looks into the police statement of any person under Section 161 of the Cr.P.C for the purpose of anticipatory or regular bail, the court must first ascertain whether such person is actually a witness or an accused person, or likely to be an accused person in respect of the offence(s) alleged. This is because, there may be situations where a person while giving his statement under Section 161 of the Cr.P.C may not be an accused, but later arrayed as one. In such a scenario the courts must be mindful of the fact that because the investigation is still 1246 ongoing, a person who was originally a witness may happen to be later arrayed as an accused person. If the court was to blindly place reliance on statement of such a person merely because he is not named in the first information report, without first seeing whether such person is likely to be arrayed as an accused or not, it would lead to an absurd situation where the statement of such a person may be relied upon up until such person is arrayed as an accused. We also caution the courts, where it emerges from the material on record, that such a person is likely to be arrayed as an accused, the courts should refrain from expressing any such opinion so that the investigation is not prejudiced in any manner. Allegations of third-degree methods
54. Besides the above, we would also like to make ourselves very clear that the investigating agency shall not adopt any third-degree methods or shall not coerce or exert any undue pressure or bring any undue influence on any of the witnesses or any of the co-accused to make statements that may suit the State. Tomorrow, if any complaint is made before the court in this context with some cogent material, be it the trial Court or the High Court or the Supreme Court, the same shall be viewed very seriously. It is expected of the investigating agency to carry out a fair, impartial and transparent investigation, more particularly, in accordance with law.
55. Before we close this matter, we make it further clear that if the petitioners are ultimately arrested, remanded and thereafter sent to judicial custody and if any regular bail application is filed, the same shall be considered on its own merits in accordance with law. It is needless to say that the principles of grant of anticipatory bail substantially differ from the principles of grant of regular bail. It is for the Court concerned to apply the correct principles of law so far as the grant of regular bail is concerned and decide the same accordingly.
56. With the aforesaid, these Special Leave Petitions are disposed of.
57. If the petitioners have any further apprehension that they may be ill-treated, they can approach the High Court and obtain the very same relief that the High Court has granted in favour of the other witnesses. [2025] 5 S.C.R. P Krishna Mohan Reddy v. The State of Andhra Pradesh SPECIAL LEAVE PETITION (CRL.) NO. 7534 OF 2025 1. This petitioner has already been arrested in connection with Crime No.21 of 2024 registered at CID Police Station, Mangalagiri, Guntur District, State of Andhra Pradesh. 2. We are informed that the petitioner was arrested and remanded to judicial custody. While reminding him to judicial custody, the investigating officer did not pray for any police remand. After being remanded to judicial custody, according to the State, the investigating officer has now moved an application seeking police remand of the petitioner. 3. We do not say anything in this regard because it will be for the Court concerned to consider whether once an accused is remanded to judicial custody whether thereafter the Investigating Officer can pray for police remand or not. 4. Be that as it may, if any application for regular bail is filed by the petitioner, the same shall be looked into by the Court concerned on its own merits by applying the well-settled principles of grant of regular bail in accordance with law. 5. With the aforesaid, the Special Leave Petition is disposed of. 6. Pending applications, if any, shall also stand disposed of. Result of the case: Special Leave Petitions disposed of. †Headnotes prepared by: Divya Pandey