A) ABSTRACT / HEADNOTE

The judgment in State of U.P. v. Gayatri Prasad Prajapati addresses the legal permissibility and judicial discipline required while granting interim bail on medical grounds to an accused charged with serious sexual offences under the Indian Penal Code and the Protection of Children from Sexual Offences Act. The Supreme Court examined whether the High Court was justified in granting interim bail solely on medical considerations when adequate and continuous medical treatment was already being provided under State supervision in premier government hospitals. The Court scrutinised the medical records, medical board report, and treatment history of the respondent, a former minister, and found that the High Court failed to consider material evidence on record, including the findings of a duly constituted medical board and reports from a super-speciality hospital. The judgment reiterates that humane treatment of prisoners is a constitutional obligation, yet emphasises that medical bail cannot be granted mechanically or sympathetically without recording satisfaction that continued custody would jeopardise the life or health of the accused. The decision underscores the principle that judicial discretion in bail matters must be exercised with due application of mind to the complete factual matrix, particularly when allegations involve grave offences and when the accused is already receiving specialised treatment under State care.

Keywords: Interim Bail, Medical Grounds, Judicial Discretion, Prisoner’s Rights, Serious Sexual Offences

B) CASE DETAILS

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The appeal arose from an order of the Allahabad High Court granting interim bail on medical grounds to the respondent, who was accused of grave sexual offences including gang rape and offences under the POCSO Act. The respondent had earlier been denied regular bail on multiple occasions, and his initial bail was cancelled before release. Subsequently, prolonged medical treatment became the basis for repeated applications seeking temporary liberty. The High Court granted interim bail for two months citing the respondent’s medical condition and the COVID-19 pandemic. The State challenged this order before the Supreme Court, asserting that adequate medical treatment was already being provided and that the High Court ignored crucial medical reports.

The Supreme Court confined itself strictly to examining the legality of interim bail on medical grounds and consciously refrained from commenting on the merits of the pending regular bail application. The background reveals a pattern where medical treatment in custody was continuously facilitated through King George Medical University and later through Sanjay Gandhi Postgraduate Institute of Medical Sciences, both premier government institutions. The judgment therefore operates at the intersection of prisoners’ right to health and judicial responsibility in bail adjudication.

D) FACTS OF THE CASE

The respondent, a former minister, was accused in Crime No. 29 of 2017 under Sections 376D, 376, 511, 504, 506 IPC read with Sections 3 and 4 of the POCSO Act. The FIR was registered pursuant to directions issued by the Supreme Court in a criminal writ petition. Though bail was initially granted by the trial court, it was cancelled by the High Court even before the respondent could be released. Subsequent bail applications were also rejected.

On 03.05.2019, the respondent was admitted to K.G.M.U., Lucknow, where he remained hospitalised for more than seven months and was discharged on 17.01.2020 in stable condition. The diagnosis recorded was “UTI with Diabetes Mellitus with HTN with Bamboo spine with seronegative Spondyloarthropathy”. During pendency of Bail Application No. 5743 of 2019, the High Court directed constitution of a medical board and further medical evaluation.

On 04.06.2020, the respondent was shifted to S.G.P.G.I.M.S., Lucknow, a tertiary super-speciality hospital, where further evaluation was undertaken. The medical board reported that there was no major disparity in treatment and that the respondent could continue treatment even at the jail hospital, subject to specialist consultations. Despite these reports, the High Court granted interim bail on 03.09.2020. This order became the subject of appeal.

E) LEGAL ISSUES RAISED

i. Whether interim bail on medical grounds can be granted when adequate treatment is already being provided in custody?
ii. Whether the High Court erred by ignoring material medical reports placed on record?
iii. Whether judicial discretion in bail matters requires recorded satisfaction of medical necessity?

F) PETITIONER / APPELLANT’S ARGUMENTS

The counsels for the petitioner submitted that the respondent had received continuous and specialised medical treatment in both K.G.M.U. and S.G.P.G.I.M.S. It was argued that the medical board report dated 10.06.2020 explicitly stated that the respondent’s condition was stable and manageable even within the jail hospital framework. The State contended that the High Court relied on selective and outdated medical records while completely disregarding later reports demonstrating medical stability. Emphasis was placed on the condition imposed by the High Court that the respondent would ordinarily reside at his residence, which contradicted the very basis of medical bail.

G) RESPONDENT’S ARGUMENTS

The counsels for the respondent submitted that humane treatment of prisoners is a constitutional obligation and that shifting the respondent between hospitals indicated inadequacy of care. It was argued that certain diagnostic facilities were unavailable at K.G.M.U., necessitating referral to S.G.P.G.I.M.S. The respondent asserted that continued hospitalisation was essential and that incarceration would expose him to serious health risks during the COVID-19 pandemic.

H) RELATED LEGAL PROVISIONS

i. Section 376D IPC
ii. Section 376 IPC
iii. Sections 3 and 4, POCSO Act
iv. Article 21 of the Constitution of India (right to life and health)

I) JUDGEMENT

The Supreme Court held that medical bail cannot be granted merely on humanitarian considerations without assessing whether continued custody would obstruct necessary treatment. The Court noted that the respondent had been under constant medical supervision for over a year and that his condition was stable and controlled. The High Court failed to consider the medical board report and final evaluation of S.G.P.G.I.M.S., both of which indicated adequacy of treatment.

The Court observed that no finding was recorded by the High Court that further treatment was unavailable within custody. The assumption that K.G.M.U. lacked adequate facilities was contradicted by documentary evidence. The Supreme Court held the High Court’s order to be unsustainable due to non-application of mind and set it aside.

a) RATIO DECIDENDI

The ratio of the judgment lies in the principle that interim bail on medical grounds requires demonstrable necessity. Adequate medical treatment within custody negates the basis for temporary liberty. Judicial discretion must be exercised upon complete consideration of medical evidence. Sympathy cannot replace legal reasoning.

b) OBITER DICTA

The Court reiterated that humane treatment of prisoners is mandatory and flows from Article 21. However, humane treatment does not imply automatic entitlement to bail. The State’s obligation is to ensure proper medical care, not unconditional release.

c) GUIDELINES

i. Courts must examine entire medical records before granting medical bail.
ii. Medical board reports must be specifically considered.
iii. Bail orders must record clear satisfaction regarding inadequacy of custodial treatment.
iv. Conditions of bail must correlate with the purpose of release.

J) CONCLUSION & COMMENTS

The judgment reinforces discipline in bail jurisprudence and clarifies that medical grounds are exceptional, not routine. It safeguards the balance between prisoner rights and societal interest. The Supreme Court correctly intervened to prevent dilution of standards in cases involving serious sexual offences. The ruling strengthens judicial accountability and reiterates that State-provided medical care, when adequate, cannot be undermined by speculative apprehensions.

K) REFERENCES

a) Important Cases Referred

i. State of U.P. v. Gayatri Prasad Prajapati, [2020] 7 S.C.R. 959

b) Important Statutes Referred

i. Indian Penal Code, 1860
ii. Protection of Children from Sexual Offences Act, 2012