Padala Ramana vs The State Of Andhra Pradesh on 13 July, 2026

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    Andhra Pradesh High Court – Amravati

    Padala Ramana vs The State Of Andhra Pradesh on 13 July, 2026

    Date of reserved for orders :
    Date of pronouncement        :
    Date of uploading        :
     APHC010283342026
                         IN THE HIGH COURT OF ANDHRA PRADESH
                                       AT AMARAVATI               [3521]
                                (Special Original Jurisdiction)
    
                         MONDAY, THE 13th DAY OF JULY 2026
                                     PRESENT
               THE HONOURABLE DR JUSTICE Y. LAKSHMANA RAO
                          CRIMINAL PETITION NO: 4563/2026
    Between:
       1. PADALA RAMANA, S/O. VENKATESWARLU, AGED ABOUT 35
          YEARS,SECURITY    GAURD,      NARSIPATNAM, ANAKAPALLI
          DIST.,ANDHRA PRADESH- 531116.
                                                  ...PETITIONER/ACCUSED
                                       AND
       1. THE STATE OF ANDHRA PRADESH, , REP.BY ITS PUBLIC
          PROSECUTOR,    THROUGH       STATIONHOUSE      OFFICER,
          NARSIPATNAM TOWN POLICE STATION, ANAKAPALLI DISTRICT.
       2. YEKA SRI SATYA SIVA PRASAD ALIAS SIVA, , S/O. RAJABABU,
          HINDU,AGED ABOUT 34 YEARS, K VELAMA BY CASTE, YSRCP
          LEADER,R/O.   D.NO.    4-173,  DHANIMIREDDY     VEEDHI,
          NARSIPATNAM MUNICIPALITY,ANAKAPALLI DIST.
       3. SURLA APPALANAIDU ALIAS BALIGATTAM NAIDU, , S/O.
          DEMUDU,AGED ABOUT 40 YEARS, CAST BY K VELAMA, R/O.
          BALIGATTAM VILLAGE,NARSIPATNAM MUNICIPALITY, ANAKAPALLI
          DIST.
                                          ...RESPONDENT/COMPLAINANT(S):
    Counsel for the Petitioner/accused:
       1. V V SATISH
    Counsel for the Respondent/complainant(S):
                                            2
                                                                                  Dr.YLR, J
                                                                     Crl.P.No.4563 of 2026
                                                                         Dated 13.07.2026
    
         1. P NANILU NAIDU
         2. PUBLIC PROSECUTOR
    The Court made the following:
    ORDER:

    The Criminal Petition is filed under Section 483(2) of the Bharatiya

    Nagarik Suraksha Sanhita, 2023 (for brevity, „the BNSS‟), by the Petitioner/De-

    SPONSORED

    facto complainant seeking cancellation of the bail granted to Respondent

    Nos.2 and 3/Accused Nos.3 and 4 in connection with Crl.M.P.No.190 of 2026

    in Crime No.60 of 2026 on the file of the learned Additional Judicial First Class

    Magistrate, Narsipatnam.

    2. Heard the learned Counsel for the Petitioner, learned Counsel for the

    Respondent Nos.2 and 3 and the learned Assistant Public Prosecutor.

    3. The case of the prosecution is that on 27.04.2026 at about 8:30 p.m.,

    while the de facto complainant was on duty as a security guard at the Srushti

    Kshetram construction site, the Petitioner/Accused, along with others, came to

    the spot in a car. They allegedly damaged a motorcycle at the site, wrongfully

    restrained the complainant, assaulted him causing injuries, and threatened

    him with dire consequences.

    4. Mr. V.V. Satish, learned Counsel for the Petitioner submits that the

    impugned order granting bail is illegal, arbitrary, and contrary to the settled

    principles governing the grant of bail, particularly having regard to the gravity

    of the offence and the grievous injuries sustained by the victim. It is submitted

    that the learned Court below failed to appreciate the seriousness of the
    3
    Dr.YLR, J
    Crl.P.No.4563 of 2026
    Dated 13.07.2026

    allegations, the medical evidence, and the fact that the investigation was at a

    nascent stage, with the prime accused yet to be apprehended and crucial

    evidence still to be collected. It is further contended that the accused are

    politically and financially influential persons who are likely to tamper with the

    prosecution evidence, threaten witnesses, and obstruct a fair investigation.

    The Petitioner also submits that the reasons assigned by the Court below for

    granting bail are unsustainable and contrary to the settled law laid down by

    the Supreme Court. Accordingly, the Petitioner seeks cancellation of the bail

    granted to the Respondents.

    5. Per contra, Sri A. Sai Rohit, learned Assistant Public Prosecutor,

    submits that the henchmen of Respondent Nos.2 and 3/Accused Nos.3 and 4

    threatened the Petitioner/De-facto complainant with dire consequences,

    thereby violated the bail conditions imposed by the learned Trial Court. He

    further submits that the learned Trial Court failed to take into consideration the

    gravity and seriousness of the offences while granting bail and released the

    accused within a short span of time. He, therefore, prayed that the Criminal

    Petition be allowed.

    6. Sri P. Nanilu Naidu, learned Counsel for the Respondent Nos.2 and

    3/Accused Nos.3 and 4 submits that the petition is devoid of merit, as there is

    no material to establish that the accused has misused the liberty granted by

    the Court. It is contended that the accused has faithfully complied with all the

    conditions of bail, has neither attempted to tamper with the prosecution
    4
    Dr.YLR, J
    Crl.P.No.4563 of 2026
    Dated 13.07.2026

    evidence nor influenced any witness, and has been regularly appearing before

    the trial Court. It is further submitted that the investigation has been completed

    and the charge sheet has been filed. In the absence of any supervening

    circumstance or cogent material demonstrating misuse of liberty, the

    extraordinary power of cancellation of bail cannot be invoked. The learned

    counsel further contends that the petitioner is, in effect, seeking a review of the

    order granting bail, which is impermissible in proceedings for cancellation of

    bail. Accordingly, it is prayed that the petition be dismissed.

    7. Thoughtful consideration is bestowed on the arguments advanced by

    the learned Counsel for both sides. I have perused the entire record.

    8. In the light of the case of the prosecution and the contentions of the

    learned Counsel for both the sides, now the point for consideration is:

    “Whether the Petitioner is entitled for cancellation of bail?”

    9. As seen from the record, the alleged offence took place on 24.05.2026.

    The FIR was registered in Crime No.60 of 2026 for the offences punishable

    under Sections 126(2), 115(2), 324(4), and 351(2) read with Section 3(5) of the

    Bharatiya Nyaya Sanhita, 2023 (for brevity, „the BNS‟). As the Petitioner

    sustained grievous injuries, the Investigating Officer subsequently added

    Section 118(2) of „the BNS‟.

    10. The Respondent Nos.2 and 3 were arrested on 06.05.2026 and

    produced before the learned Magistrate. They were remanded to judicial

    custody on 07.05.2026 for a period of fifteen days. By order dated 11.05.2026,
    5
    Dr.YLR, J
    Crl.P.No.4563 of 2026
    Dated 13.07.2026

    the learned Trial Court enlarged Respondent Nos.2 and 3 on bail, observing

    that they had been in judicial custody since 06.05.2026, that L.Ws.1 to 5 had

    been examined, the scene observation report had been prepared, and the

    rough sketch of the scene of offence had also been drawn. The learned Trial

    Court further observed that the material part of the investigation had been

    substantially completed, except for the filing of the charge sheet. On the said

    reasoning, Respondent Nos.2 and 3 were released on bail subject to the

    following conditions:

    1. The Petitioners/Accused Nos.3 and 4 are ordered to be enlarged on
    bail on executing a personal bond in a sum of Rs.20,000/- each (Rupees
    Twenty Thousand only) with two sureties for a like sum each to the
    satisfaction of this Court.

    2. The Petitioners/Accused Nos.3 and 4 shall appear before the Sho,
    Narsipatnam Town PS once in a week i.e., on every Thursday in between
    9:00 PM and 12:00 noon for a period of two months or until filing of the
    charge sheet, which ever is earlier.

    3. The Petitioners/Accused Nos.3 and 4 shall cooperate with the
    investigation agency whenever they require their presence.

    4. The Petitioners/Accused Nos.3 and 4 shall not threaten the witnesses
    in this case or tamper any evidence.

    11. The learned Counsel for the Petitioner relied on the judgement of the

    Hon‟ble Apex Court in Mahipal v. Rajesh Kumar Alias Polia 1, wherein at

    paragraph Nos.17 and 22 it is held as under:

    “17…Where a court considering an application for bail fails to consider
    relevant factors, an appellate court may justifiably set aside the order
    granting bail. An appellate court is thus required to consider whether the
    order granting bail suffers from a non-application of mind or is not borne
    out from a prima facie view of the evidence on record. It is thus necessary
    for this Court to assess whether, on the basis of the evidentiary record,
    there existed a prima facie or reasonable ground to believe that the
    accused had committed the crime, also taking into account the
    seriousness of the crime and the severity of the punishment. The order of
    the High Court in the present case, insofar as it is e relevant reads:

    (Rajesh Kumar case¹, SCC OnLine Raj paras 2-4)

    1
    (2020) 2 Supreme Court Cases 118
    6
    Dr.YLR, J
    Crl.P.No.4563 of 2026
    Dated 13.07.2026

    22. Without expressing any finding or opinion on the merits of the case, a
    case has been made out for setting aside the bail granted by the High
    Court. The High Court has manifestly erred in not taking note of the
    material which has been adverted to above. The order passed by the High
    Court fails to notice material facts and shows a non-application of mind to
    the seriousness of the crime and the circumstances referred to earlier
    which ought to have been taken into consideration.”

    12. In Mahipal case, the charge was under Section 302 of „the I.P.C.,‟

    whereas, in the present case, the charge is under Section 118(2) of „the BNS‟.

    13. It is not the case of the Petitioner that Respondent Nos.2 and 3

    themselves threatened the Petitioner with dire consequences. The specific

    allegation of the Petitioner is that the henchmen of Respondent Nos.2 and 3

    heckled and threatened him with dire consequences. In that regard, the

    Petitioner lodged a complaint before the Station House Officer, Narsipatnam

    Rural Police Station. Pursuant thereto, a preliminary enquiry was conducted,

    and the Station House Officer submitted a report to the Sub-Divisional Police

    Officer, Narsipatnam, confirming the allegations made by the Petitioner.

    However, the report also records that the persons who allegedly threatened

    the Petitioner were not identified, and that the complaint disclosed only a non-

    cognizable offence.

    13. The Respondent Nos. 2 and 3 have filed counter affidavit and submitted

    that the criminal petition seeking cancellation of bail is misconceived, politically

    motivated, and filed only to harass them. They submit that the learned

    Magistrate granted bail through a reasoned order after considering the case

    diary, the progress of investigation, and imposing stringent conditions, which

    they have fully complied with. They deny all allegations of political influence,
    7
    Dr.YLR, J
    Crl.P.No.4563 of 2026
    Dated 13.07.2026

    witness intimidation, or tampering with evidence, stating that the claims are

    vague, unsupported, and that key witnesses have already been examined

    while material objects are in police custody. They argue that the absconding

    status of Accused No. 1 is irrelevant to their case, as each accused is entitled

    to independent consideration on the merits of their own case.They assert that

    there are no supervening circumstances or misuse of bail warranting

    cancellation, and therefore pray for dismissal of the criminal petition.

    14. In Dolat Ram v. State of Haryana2 , the Hon‟ble Supreme Court held that bail

    once granted should not be cancelled in a mechanical manner. Very cogent and

    overwhelming circumstances are necessary for cancellation. The relevant paragraph

    No.4, is extracted as under:

    “4. Rejection of bail in a non-bailable case at the initial stage and the cancellation
    of bail so granted, have to be considered and dealt with on different basis. Very
    cogent and overwhelming circumstances are necessary for an order directing the
    cancellation of the bail, already granted. Generally speaking, the grounds for
    cancellation of bail, broadly (illustrative and not exhaustive) are: interference or
    attempt to interfere with the due course of administration of justice or evasion or
    attempt to evade the due course of justice or abuse of the concession granted to
    the accused in any manner. The satisfaction of the court, on the basis of material
    placed on the record of the possibility of the accused absconding is yet another
    reason justifying the cancellation of bail. However, bail once granted should not
    be cancelled in a mechanical manner without considering whether any
    supervening circumstances have rendered it no longer conducive to a fair trial to
    allow the accused to retain his freedom by enjoying the concession of bail during
    the trial. These principles, it appears, were lost sight of by the High Court when it
    decided to cancel the bail, already granted. The High Court it appears to us
    overlooked the distinction of the factors relevant for rejecting bail in a non-
    bailable case in the first instance and the cancellation of bail already granted.”

    15. In Raghubir Singh v. State of Bihar 3 , the Supreme Court observed that

    cancellation is warranted where the accused misuses the liberty granted by the Court

    and at paragraph No.22 it is held as under:

    2

    (1995) 1 SCC 349
    3
    (1986) 4 SCC 481
    8
    Dr.YLR, J
    Crl.P.No.4563 of 2026
    Dated 13.07.2026

    “22. The result of our discussion and the case-law is this : An order for release on
    bail made under the proviso to Section 167(2) is not defeated by lapse of time,
    the filing of the charge-sheet or by remand to custody under Section 309(2). The
    order for release on bail may however be cancelled under Section 437(5) or
    Section 439(2). Generally the grounds for cancellation of bail, broadly, are,
    interference or attempt to interfere with the due course of administration of
    justice, or evasion or attempt to evade the course of justice, or abuse of the
    liberty granted to him. The due administration of justice may be interfered with by
    intimidating or suborning witnessses, by interfering with investigation, by creating
    or causing disappearance of evidence etc. The course of justice may be evaded
    or attempted to be evaded by leaving the country or going underground or
    otherwise placing himself beyond the reach of the sureties. He may abuse the
    liberty granted to him by indulging in similar or other unlawful acts. Where bail
    has been granted under the proviso to Section 167(2) for the default of the
    prosecution in not completing the investigation in 60 days, after the defect is
    cured by the filing of a charge-sheet, the prosecution may seek to have the bail
    cancelled on the ground that there are reasonable grounds to believe that the
    accused has committed a non-bailable offence and that it is necessary to arrest
    him and commit him to custody. In the last mentioned case, one would expect
    very strong grounds indeed.”

    16. In Puran v. Rambilas4, the Hon‟ble Apex Court held that bail can be cancelled

    where the order granting bail is unjustified, suffers from serious infirmities, or ignores

    relevant material, saying so, wherein at paragraph No.10, it is held as under:

    “10. Mr Lalit next submitted that once bail has been granted it should not be
    cancelled unless there is evidence that the conditions of bail are being infringed.
    In support of this submission he relies upon the authority in the case of Dolat
    Ram v. State of Haryana
    [(1995) 1 SCC 349 : 1995 SCC (Cri) 237] . In this case it
    has been held that rejection of bail in a non-bailable case at the initial stage and
    the cancellation of bail already granted have to be considered and dealt with on
    different basis. It has been held that very cogent and overwhelming
    circumstances are necessary for an order directing the cancellation of the bail
    already granted. It has been held that generally speaking the grounds for
    cancellation of bail broadly are interference or attempt to interfere with the due
    course of administration of justice or evasion or attempt to evade the due course
    of justice or abuse of the concession granted to the accused in any manner. It is,
    however, to be noted that this Court has clarified that these instances are merely
    illustrative and not exhaustive. One such ground for cancellation of bail would be
    where ignoring material and evidence on record a perverse order granting bail is
    passed in a heinous crime of this nature and that too without giving any reasons.
    Such an order would be against principles of law. Interest of justice would also
    require that such a perverse order be set aside and bail be cancelled. It must be
    remembered that such offences are on the rise and have a very serious impact
    on the society. Therefore, an arbitrary and wrong exercise of discretion by the
    trial court has to be corrected.”

    4

    (2001) 6 SCC 338
    9
    Dr.YLR, J
    Crl.P.No.4563 of 2026
    Dated 13.07.2026

    17. The Hon‟ble Apex Court in Himanshu Sharma v. State of M.P5, at paragraph

    No.11 it is held as under:

    “11. Law is well settled by a catena of judgments rendered by this Court that the
    considerations for grant of bail and cancellation thereof are entirely different. Bail
    granted to an accused can only be cancelled if the Court is satisfied that after
    being released on bail:

    (a) the accused has misused the liberty granted to him;

    (b) flouted the conditions of bail order;

    (c) that the bail was granted in ignorance of statutory provisions restricting the
    powers of the Court to grant bail;

    (d) or that the bail was procured by misrepresentation or fraud.

    In the present case, none of these situations existed.”

    18. In Neeru Yadav v. State of U.P6, the Hon‟ble Supreme Court at paragraph

    No.12, held as under:

    “12. We have referred to certain principles to be kept in mind while granting bail,
    as has been laid down by this Court from time to time. It is well settled in law that
    cancellation of bail after it is granted because the accused has misconducted
    himself or of some supervening circumstances warranting such cancellation have
    occurred is in a different compartment altogether than an order granting bail
    which is unjustified, illegal and perverse. If in a case, the relevant factors which
    should have been taken into consideration while dealing with the application for
    bail have not been taken note of, or bail is founded on irrelevant considerations,
    indisputably the superior court can set aside the order of such a grant of bail.
    Such a case belongs to a different category and is in a separate realm. While
    dealing with a case of second nature, the court does not dwell upon the violation
    of conditions by the accused or the supervening circumstances that have
    happened subsequently. It, on the contrary, delves into the justifiability and the
    soundness of the order passed by the court.”

    19. Having regard to the facts and circumstances of the case, and in view of law

    laid down by the Hon‟ble Supreme Court, this Court is of the considered view that no

    case is made out for cancellation of the bail granted to Respondent Nos.2 and 3. The

    material placed on record does not disclose any supervening circumstance

    warranting interference with the order granting bail. Equally, no material has been

    placed before this Court to establish that the Respondent Nos.2 and 3 have violated

    5
    (2024) 4 SCC 222
    6
    (2014) 16 SCC 508
    10
    Dr.YLR, J
    Crl.P.No.4563 of 2026
    Dated 13.07.2026

    the conditions of bail, attempted to tamper with the prosecution evidence, intimidated

    the witnesses, or otherwise abused the liberty granted to them. The allegations

    regarding threats are not directly attributable to Respondent Nos.2 and 3 and, in any

    event, are not supported by sufficient material to justify cancellation of bail. Since the

    investigation has already been completed and the charge sheet has been filed, the

    apprehension of interference with the investigation no longer survives. Therefore,

    this Court finds no legal or factual basis to invoke the extraordinary power of

    cancellation of bail under Section 483(2) of „the BNSS‟.

    20. It has to point that the learned Trial Court failed to take into consideration

    the gravity and seriousness of the offences while granting bail and released

    the accused within a short span of time.

    21. However, considering the apprehension expressed by the Petitioner and with

    a view to ensuring a fair and uninfluenced trial, this Criminal Petition is disposed of

    strengthening the conditions of bail imposed by the learned Additional Judicial First

    Class Magistrate, Narsipatnam, in Crl.M.P.No.190 of 2026 as follows:

    i. The Petitioner/Accused Nos.3 and 4 shall appear before the

    Station House Officer, Narsipatnam Town Police Station twice in a

    week i.e., every Monday and Thursday in between 10:00 A.M., and

    1:00 P.M., till the prime witness of the prosecution are examined by

    the learned Trial Court.

    ii. The Petitioner/Accused Nos.3 and 4 or their henchmen or their

    supporters shall not indulge the activities of threatening the

    witnesses in the case in any manner.

    11

    Dr.YLR, J
    Crl.P.No.4563 of 2026
    Dated 13.07.2026

    22. Accordingly, the Criminal Petition is disposed of. However, the Investigating

    Officer is directed to inquire into the allegation that the Respondents/Accused Nos.3

    and 4 had instigated or engaged their henchmen to threaten the Petitioner with dire

    consequences. If the allegation is found to be true, the Investigating Officer shall

    take appropriate steps to ensure the protection of the victim and initiate necessary

    action against the Respondents/Accused Nos.3 and 4. A copy of this order shall

    forward to the learned Trial Court.

    _________________________
    DR. Y. LAKSHMANA RAO, J
    Date: 13.07.2026
    KMS

    Whether the order is :

    Speaking Yes/No / Reasoned Yes/No

    Reportable Yes/No / Non-Reportable Yes/No
    12
    Dr.YLR, J
    Crl.P.No.4563 of 2026
    Dated 13.07.2026

    39
    THE HONOURABLE DR JUSTICE Y. LAKSHMANA RAO

    CRIMINAL PETITION NO: 4563/2026

    Date: 13.07.2026
    KMS



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