Supreme Court rejects sapling bail condition, ruling that planting trees cannot substitute proper legal reasoning under Section 389 CrPC for suspension of sentence.
Case in News :The Supreme Court on bizarre sapling bail conditions set aside a Madhya Pradesh High Court order imposing tree planting as a bail requirement . |
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Case Overview :
Case Name : State of Madhya Pradesh vs. [Unnamed Murder Convict]
A Bench comprising Justice Aravind Kumar and Justice NV Anjaria of the Supreme Court of India examined a Madhya Pradesh High Court order that suspended a murder convict’s sentence on the condition that he plants ten fruit-bearing or neem/peepal saplings as a social cause . The apex court found this approach contrary to the principles of bail jurisprudence emphasizing that reformative or symbolic acts cannot substitute legal grounds for bail or sentence suspension .
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Key Aspects :
Before reaching its conclusion, the Court reviewed a series of unusual conditions imposed by various High Courts, questioning their legality under criminal procedure .
- The Madhya Pradesh High Court had earlier granted bail on conditions like planting trees or tying Rakhi to victims .
- Courts even directed convicts to salute the national flag or donate to cow shelters .
- The apex court held such orders lack legal basis and dilute the seriousness of offences .
- The plant saplings bail condition was seen as a deviation from statutory bail requirements .
Legal Insights :
The Supreme Court of India referred to Section 389 of the Code of Criminal Procedure (CrPC) which requires written reasons for suspension of sentence and bail .
- Under Section 302 IPC, bail after conviction must be granted only in exceptional cases .
- Earlier rulings like Kishori Lal vs. Rupa (2004) and Vijay Kumar vs. Narendra (2002) reaffirmed that life convicts need a strong prima facie case for bail .
- The Court noted that symbolic acts like sapling planting are not recognized under CrPC or IPC, except under the new Bharatiya Nyaya Sanhita, 2023, which allows community service only for petty offences .
Court’s Verdict :
Setting aside the Madhya Pradesh High Court’s order, the Supreme Court ruled that conditions like planting trees or performing community service cannot replace legal reasoning for bail . It held that judicial populism cannot override statutory safeguards, reaffirming that bail or bail cancellation must always be based on merits, not moral symbolism .
Source – Supreme Court of India
Read also – IPC
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