The Madhya Pradesh High Court granted bail to a rape accused after considering the prosecutrix’s admission of a love relationship with him, a negative forensic report, and the period already spent in custody.
High Court Allows Bail Plea of Accused
The Madhya Pradesh High Court has granted bail to a man accused of rape and related offences after examining the circumstances of the case, including the testimony of the prosecutrix and the forensic evidence placed on record.
Justice Rajendra Kumar Vani passed the order while hearing the first bail application filed by Chhabilal Uaike in connection with a criminal case registered at Roopjhar Police Station in Balaghat district.
The applicant has been booked under provisions of the Bharatiya Nyaya Sanhita relating to rape, criminal intimidation, and house trespass, along with offences under the Information Technology Act.
Defence Relied on Prosecutrix’s Testimony
Appearing for the applicant, the defence argued that several aspects of the prosecution case weakened the allegations against the accused.
The Court was informed that during cross-examination, the prosecutrix admitted that she had been in a love relationship with the applicant. The defence also pointed to her statement that the accused had not forcibly entered her house.
According to the applicant’s counsel, these admissions raised important questions regarding the prosecution’s version of events and deserved consideration at the stage of bail.
Negative FSL Report Considered by Court
The defence further highlighted that the Forensic Science Laboratory report in the case was negative.
It was submitted that because the forensic findings did not reveal any incriminating biological material, no DNA examination was subsequently conducted by the prosecution.
The applicant also relied on photographs available in the case diary, arguing that the identity of the woman appearing in those images could not be clearly established.
These circumstances were cited to contend that the evidence against the accused was not as strong as alleged by the prosecution.
State Opposed the Bail Application
The State opposed the plea and urged the Court not to release the accused on bail.
However, after hearing both sides and examining the material available in the case diary, the High Court found that the applicant had made out a case for grant of bail.
The Court clarified that it was not expressing any opinion on the merits of the allegations and that the observations were limited to the consideration of the bail application.
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Court Notes Period of Custody
Another factor considered by the Court was the applicant’s continued incarceration.
The defence informed the Court that the accused had been in judicial custody since March 11, 2025. It was argued that the prolonged detention, coupled with the circumstances emerging from the evidence, justified his release pending trial.
Taking these factors into account, the Court exercised its discretion in favour of the applicant.
Bail Granted Subject to Conditions
Allowing the application, the High Court directed the release of the accused on furnishing a personal bond of ₹50,000 along with one solvent surety of the same amount.
The Court imposed several conditions, including cooperation with the investigation and trial, refraining from influencing witnesses, avoiding criminal activity, and not leaving India without prior permission from the competent authority.
It also clarified that any violation of the conditions would automatically render the bail order ineffective.
Key Takeaways
- Madhya Pradesh High Court granted bail to a rape accused in Balaghat district.
- The prosecutrix admitted during cross-examination that she was in a love relationship with the accused.
- The defence relied on a negative FSL report and the absence of DNA examination.
- The accused had been in judicial custody since March 2025.
- The Court clarified that it was not commenting on the merits of the case.
- Bail was granted subject to strict conditions regarding cooperation with the trial and investigation.
Case Details
Case Title: Chhabilal Uaike v. State of Madhya Pradesh
Court: Madhya Pradesh High Court
Bench: Justice Rajendra Kumar Vani
Date of Order: June 8, 2026
