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Pradeep Pradhan Vs State Govt of NCT of Delhi — Anticipatory Bail | Delhi HC (2025)

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Delhi HC
2025
Pradeep Pradhan Vs State Govt of NCT of DelhiPradeep Pradhan v. State Govt of NCT of Delhi

Dismissed¶9

Pradeep Pradhan v. State Govt of NCT of Delhi

Delhi HC12 Mar 2025BAIL APPLN./1035/2025

Case brief

AI extract

What is this about?

Interim bail extension refused — Delhi High Court, Bail Appln. 1035/2025, Pradeep Pradhan v. State Govt of NCT of Delhi, Neena Bansal Krishna, J., 12.03.2025; FIR No. 0461/2021 PS Paharganj (Sections 364A/392/397/412/34 IPC; Sections 25/27/54/59/30 Arms Act); application under S.483/S.528 BNSS 2023 r/w S.438/S.482 Cr.P.C.; repeated extension of interim bail; medical grounds; mother's cataract surgery; arrest 19.11.2021; charge sheet Feb 2022; charge framed 30.03.202; dismissal with direction to surrender on 13.03.2025.

What did the court decide?

Further extension of interim bail refused: interim bail had already been granted (order dated 24.02.2025) and extended (till 13.03.2025) on the identical ground of care of the ailing mother, whose cataract surgery was performed on 07.03.2025, and on similar grounds there is no justification for any further extension.

What the court decided

AI extract

Outcome

Dismissed

Issue for consideration

Whether the Applicant/Petitioner is entitled to a further extension of interim bail for thirty days on the ground of taking post-surgery care of his ailing mother. +1 more

Court's answer

Further extension of interim bail refused: interim bail had already been granted (order dated 24.02.2025) and extended (till 13.03.2025) on the identical ground of care of the ailing mother, whose cataract surgery was performed on 07.03.2025, and on similar grounds there is no justification for any further extension.

Ratio / Principle

Although the mother's cataract surgery took place on 07.03.2025, the learned Session Judge had nevertheless granted a further extension of interim bail till 13.03.2025 for post-surgery care; the present request rests on the same ground already availed.

Detailed headnote1 paragraphs

Bail Appln. 1035/2025 — Pradeep Pradhan v. State Govt of NCT of Delhi (High Court of Delhi, Neena Bansal Krishna, J., 12.03.2025): Application under Section 483 and Section 528 of Bhartiya Nagrik Suraksha Sanhita, 2023 read with Section 438 Cr.P.C. and Section 482 Cr.P.C. seeking a further 30-day extension of interim bail in FIR No. 0461/2021 (Sections 364A/392/397/412/34 IPC and Sections 25/27/54/59/30 of Arms Act, PS Paharganj) on the ground of post-surgery care of the applicant's ailing mother, DISMISSED. Interim bail had been granted on 24.02.2025 for 11 days (till 07.03.2025) and extended by the Sessions Court till 13.03.2025 for the same purpose; the mother's cataract surgery was performed on 07.03.2025. Held: there is no justification for further extension of interim bail on similar grounds. The Applicant was directed to surrender before the concerned Jail Superintendent on the already scheduled date of 13.03.2025.

A

$~49

IN THE HIGH COURT OF DELHI AT NEW DELHI

- BAIL APPLN. 1035/2025 & Crl.M.A. 7836/2025

PRADEEP PRADHAN .....Petitioner Through: Mr. Navlender Kumar, Advocate

Versus

STATE GOVT OF NCT OF DELHI .....Respondent Through: Mr. Utkarsh, Additional Public Prosecutor for Respondent-State with SI Manish

CORAM: HON'BLE MS. JUSTICE NEENA BANSAL KRISHNA O R D E R

% 12.03.2025

The present Bail Application under Section 483 of Bhartiya Nagrik Suraksha Sanhita, 2023 read with Section 438 Cr.P.C. and Section 528 of Bhartiya Nagrik Suraksha Sanhita, 2023 and Section 482 Cr.P.C. has been filed on behalf of the Petitioner seeking extension of interim bail in FIR No. 0461/2021, under Sections 364A/392/397/412/34 IPC and Sections 25/27/54/59/30 of Arms Act, registered at Police Station Paharganj, Delhi; for a period of thirty days.

The Petitioner was arrested in the present case on 19.11.2021. Charge sheet in the present case was filed in February, 2022 and Supplementary Charge sheet was filed in May, 2022. Charge was framed on 30.03.202 and the matter is proceeding on trial.

Vide order dated 24.02.2025, the learned Additional Session Judge granted interim bail to the Applicant for a period of 11 days i.e. till 07.03.2025 to take care of his ailing mother. Thereafter, the Applicant

This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 01/07/2025 at 00:20:16

sought extension of interim bail, which was granted by the learned Sessions Court vide order dated 07.03.2025 till 13.03.2025, again for the purpose of taking care of the ailing mother.

By this Application, further extension of interim bail for 30 days is sought by the Applicant on the ground of taking post surgery care of his mother. It is submitted that father of the Applied has died and there is no other male family member in the family and also that his wife is living separately and so, there is no one in the family to take care of his mother. 5. Learned Counsel appearing on behalf of the Applicant has submitted that the present Bail Application has been filed as the learned Session Judge, while extending the interim bail of the Applicant on 07.03.2025, has already given the mind that no further extension shall be granted, though this fact has not been mentioned in the Order.

Learned Additional Public Prosecutor for Respondent-State has argued that the interim bail cannot be converted into a regular bail and such repeated extensions are opposed to the law, as laid down by the Supreme Court and this Application has no merit and it deserves to be dismissed.

7. Submissions heard and record perused .

The Applicant was granted interim bail vide order dated 24.02.2025 and he was released from jail on 25.02.2025 to take care of his mother who had to undergo cataract surgery on 25.02.2025, but the surgery was performed on 07.03.2025. Even thereafter, the learned Session Judge granted further extension of interim bail till 13.03.2025 granted to the Applicant to enable him to take post surgery care of his mother. On similar grounds further extension of bail is sought before this

This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 01/07/2025 at 00:20:16

Court. There is no justification for further extension of interim bail. 9. The Bail Application and pending Application are hereby dismissed.

The Applicant shall surrender before the Jail Superintendent concerned on the date already scheduled for his surrender i.e. 13.03.2025.

NEENA BANSAL KRISHNA, J

MARCH 12, 2025

r

This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 01/07/2025 at 00:20:16

Issues for consideration

2 issues framed by the court

AI extract

1.
Whether the Applicant/Petitioner is entitled to a further extension of interim bail for thirty days on the ground of taking post-surgery care of his ailing mother.¶4
The court held
Further extension of interim bail refused: interim bail had already been granted (order dated 24.02.2025) and extended (till 13.03.2025) on the identical ground of care of the ailing mother, whose cataract surgery was performed on 07.03.2025, and on similar grounds there is no justification for any further extension.ratio¶8
2.
Whether interim bail may be repeatedly extended such that it is converted into regular bail, contrary to the law laid down by the Supreme Court (as urged by the State).medium confidence¶6

Statutes considered

6 provisions across 4 enactments

AI extract

Bhartiya Nagrik Suraksha Sanhita, 2023483¶1 528¶1
Cr.P.C.438¶1 482¶1
IPC364A/392/397/412/34¶1
Arms Act25/27/54/59/30¶1

Procedural history

How this case reached the court

AI extract

Order under challenge
Order of the learned Sessions Court dated 07.03.2025 extending the Applicant's interim bail till 13.03.2025; per counsel, the Sessions Judge had also indicated that no further extension would be granted, though this was not recorded in the order.¶3
Sessions Court · 07.03.2025
Prior proceeding
Petitioner arrested on 19.11.2021; charge sheet filed February 2022; supplementary charge sheet May 2022; charge framed on 30.03.202 [sic]; trial proceeding.¶2
Prior proceeding
Interim bail granted for 11 days i.e. till 07.03.2025 by the learned Additional Session Judge vide order dated 24.02.2025 to take care of the Applicant's ailing mother.¶3
Prior proceeding
Applicant released from jail on 25.02.2025; mother's cataract surgery, scheduled for 25.02.2025, was performed on 07.03.2025.¶8

Parties & counsel

AI extract

petitioner
PRADEEP PRADHAN¶header-parties
Mr. Navlender Kumar
respondent
STATE GOVT OF NCT OF DELHI¶header-parties
Mr. Utkarsh

Coram

AI extract

Neena Bansal Krishnaauthor¶header-coram

Case details

As recorded by the court registry

Court: Delhi HC
Decided on: 12 Mar 2025 · March
Registered: 11 Mar 2025
Case no.: BAIL APPLN./1035/2025
CNR: DLHC010129412025
Topic: Anticipatory Bail
Bench: Neena Bansal Krishna
Case type: BAIL APPLN.

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Cite this judgement

Pradeep Pradhan v. State Govt of NCT of Delhi, BAIL APPLN./1035/2025 (DEL), decided on 12 March 2025.

The High Court of Delhi publishes no neutral citation for this judgement — cite it by case number and date of decision.

Statutes6

Bhartiya Nagrik Suraksha Sanhita, 2023483 · 528
Cr.P.C.438 · 482
IPC364A/392/397/412/34
Arms Act25/27/54/59/30

View all statutes

Procedural history4

Order of the learned Sessions Court dated 07.03.2025 extending the Applicant's interim bail till 13.03.2025; per counsel, the Sessions Judge had also indicated that no further extension would be granted, though this was not recorded in the order.Sessions Court · 07.03.2025
Petitioner arrested on 19.11.2021; charge sheet filed February 2022; supplementary charge sheet May 2022; charge framed on 30.03.202 [sic]; trial proceeding.
Interim bail granted for 11 days i.e. till 07.03.2025 by the learned Additional Session Judge vide order dated 24.02.2025 to take care of the Applicant's ailing mother.

View full history

Bench / Coram

Neena Bansal Krishna

Parties & counsel