Disposed¶17

Uma Shankar Pal v. State of U.P. and Another

Allahabad HC29 Jan 2026NA528/1623/2026

Case brief

AI extract

What is this about?

Allahabad High Court; APPLICATION U/S 528 BNSS No. 1623 of 2026; Uma Shankar Pal v. State of U.P. and Another; quashing of proceedings; Criminal Case No. 218 of 2020; Case Crime No. 227 of 2019; Sections 15, 17, 30 Indian Medical Council Act, 1956; Sections 419, 420 IPC; Police Station Madihan, District Mirzapur; cognizance/summoning order dated 31.08.2020; Additional Civil Judge (Junior Division) Mirzapur; charge-sheet filed; withdrawal with liberty; regular bail application; Satender Kumar Antil v. CBI (2022) 10 SCC 51 Category A; Sanjay Kumar Pachori, J.; disposed of May 12, 2026.

What did the court decide?

Liberty to withdraw the application and to file a regular bail application before the court of competent jurisdiction; prayer for quashing refused. ¶17

Uma Shankar Pal vs State of U.P. and Another — Allahabad HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Liberty to withdraw the application and to file a regular bail application before the court of competent jurisdiction; prayer for quashing refused.

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Issue for consideration

Whether the entire proceedings of Criminal Case No. 218 of 2020 (arising out of Case Crime No. 227 of 2019) and the cognizance/summoning order dated 31.08.2020 should be quashed. +1 more

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Court's answer

Upon considering the facts and circumstances of the case, the prayer made by learned counsel for the applicant (for quashing of the proceedings and the cognizance/summoning order) is refused.

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Ratio / Principle

Liberty is granted to the applicant to withdraw the application and file a regular bail application before the court of competent jurisdiction; the application stands disposed of with the aforesaid liberty.

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Key takeaways

In case a bail application is filed by the applicant, it shall be decided in the light of the observations of the Supreme Court in Satender Kumar Antil v. Central Bureau of Investigation, (2022) 10 SCC 51, whereby bail applications of Category A accused (against whom charge-sheet has been submitted on appearance) may be decided without the accused being taken in physical custody or by granting interim bail till the bail application is decided.obiter¶13

Detailed headnote1 paragraphs

Allahabad High Court (Sanjay Kumar Pachori, J.), May 12, 2026 — Application under S.528 BNSS No. 1623 of 2026 by Uma Shankar Pal seeking quashing of the entire proceedings of Criminal Case No. 218 of 2020, arising out of Case Crime No. 227 of 2019 under Sections 15, 17, 30 of the Indian Medical Council Act, 1956 and Sections 419 and 420 IPC, Police Station Madihan, District Mirzapur, and of the cognizance/summoning order dated 31.08.2020 passed by the Additional Civil Judge (Junior Division), Mirzapur. Upon consideration, the prayer for quashing was refused; learned counsel thereupon sought leave to withdraw the application with liberty to file a regular bail application before the competent court. The application was disposed of with that liberty, any bail application so filed to be decided in the light of the Supreme Court's observations in Satender Kumar Antil v. Central Bureau of Investigation, (2022) 10 SCC 51 regarding Category A accused (charge-sheeted on appearance), whose bail applications may be decided without physical custody or by granting interim bail till decision.

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HIGH COURT OF JUDICATURE AT ALLAHABAD

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APPLICATION U/S 528 BNSS No. - 1623 of 2026

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Uma Shankar Pal

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.....Applicant(s)

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	Versus
State of U.P. and Another	.....Opposite Party(s)
Counsel for Applicant(s) Counsel for Opposite Party(s)	: Rajendra Prasad, Satya Prakash Shukla : G.A.

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Court No. - 76

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HON'BLE SANJAY KUMAR PACHORI, J.

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Sri Satya Prakash Shukla, learned counsel for the applicant and Sri Kameshwar Singh, learned A.G.A. for the State and perused the material on record.

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The present application under Section 528 of Bhartiya Nagrik Suraksha Sanhita, 2023 has been filed by the applicant to quash the entire proceedings of Criminal Case No. 218 of 2020 arising out of Case Crime No. 227 of 2019, under Sections 15, 17, 30 of Indian Medical Council Act, 1956 and Section 419 and 420 of I.P.C., Police Station- Madihan, District- Mirzapur as well as cognizance/summoning order dated 31.08.2020, pending in the Court of Additional Civil Judge (Junior Division), Mirzapur.

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Learned counsel for the applicant submits that applicant was not arrested during the course of investigation and the charge-sheet has been submitted against him. It is further submitted that the offence is punishable up to 7 years imprisonment.

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Upon considering the facts and circumstances of the case, the prayer made by learned counsel for the applicant is, hereby, refused.

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After some arguments, learned counsel for the applicant wants to withdraw the application with liberty to file a regular bail application before the court of competent jurisdiction.

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In case bail application is filed by the learned counsel for the applicant, the same shall be decided in the light of the observations made in the judgment rendered by the Supreme Court in Satender Kumar Antil Vs. Central

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NA528 No. 1623 of 2026

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Bureau of Investigation & Another, (2022) 10 SCC 51, wherein the Supreme Court considering the category(A) as mentioned in the paragraph no. 2, bail applications of such accused against which charge-sheet has been submitted on appearance may be decided without the accused being taken in physical custody or by granting interim bail till the bail application is decided. It has been observed that at the cost of repetition, we wish to state that, in category A, one would expect a better exercise of discretion on the part of the court in favour of the accused.

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The application stands disposed of with the aforesaid liberty.

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May 12, 2026 Ishan

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(Sanjay Kumar Pachori,J.)

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Digitally signed by :- ISHAN JAISWAL High Court of Judicature at Allahabad

Uma Shankar Pal v. State of U.P. and Another

Case brief

What is this about?

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Uma Shankar Pal v. State of U.P. and Another

Case brief

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