Introduction
In a significant reaffirmation of the constitutional principle that “bail is the rule and jail is the exception,” the Supreme Court of India has granted bail to Aadya Prasad Tiwari, an accused in the high-profile case relating to the death of Mahant Narendra Giri, the former President of the Akhil Bharatiya Akhara Parishad. The Court’s ruling underscores the importance of speedy trial, proportionality of pre-trial detention, and individual role assessment while deciding bail applications, especially in cases where trials are likely to take an inordinately long time to conclude.
The decision was delivered by a Bench comprising Justice Dipankar Datta and Justice Satish Chandra Sharma, which set aside the Allahabad High Court’s order rejecting Tiwari’s bail plea.
Background of the Case
Mahant Narendra Giri was found dead under suspicious circumstances inside his Math in Prayagraj on September 20, 2021. His death sparked widespread public attention due to his stature as a prominent religious leader.
Following the incident, FIR No. 322 of 2021 was registered at George Town Police Station, Prayagraj, initially under Section 306 of the Indian Penal Code (IPC), alleging abetment to suicide. Aadya Prasad Tiwari was arrested on September 22, 2021.
Subsequently, the investigation took a more serious turn. The charge sheet filed on November 18, 2021 invoked Sections 120-B (criminal conspiracy) and 302 (murder) IPC, transforming the case from one of alleged abetment to suicide into a murder prosecution.
Tiwari’s plea for bail was rejected by the Allahabad High Court on October 14, 2025, prompting him to approach the Supreme Court.
Supreme Court’s Analysis and Reasoning
While allowing the criminal appeal, the Supreme Court laid emphasis on two crucial aspects:
1. Extraordinary Delay in Trial
The prosecution proposed to examine around 150 witnesses, yet only three witnesses had been examined till date. The Bench noted that this indicated an extremely slow pace of trial, making it evident that the proceedings were unlikely to conclude in the near future.
The Court observed:
“It is, therefore, clear that the trial is likely to take time to conclude.”
This observation aligns with consistent Supreme Court jurisprudence that prolonged incarceration pending trial violates Article 21 of the Constitution, which guarantees the right to life and personal liberty.
2. Role of the Accused
The Bench also took note of the fact that Aadya Prasad Tiwari did not appear to be the principal accused in the case. The Court stressed that individual culpability and role attribution are essential considerations while deciding bail, particularly in conspiracy or multi-accused cases.
The Court held that continued detention of the appellant, given the circumstances, was not necessary.
Bail Granted: Conditions Imposed
Granting bail, the Supreme Court directed that Aadya Prasad Tiwari be released subject to the following conditions:
- Furnishing bail bonds to the satisfaction of the trial court
- Strict compliance with conditions imposed by the trial court
- The appellant shall not directly or indirectly induce, threaten, or promise any person acquainted with the facts of the case
- The appellant must diligently attend trial proceedings, unless exempted
- Any violation may be treated as a breach of bail conditions, leading to cancellation of bail
The Court also clarified that the observations made were only for the purpose of deciding the bail plea and shall not be construed as findings on merits.
Legal Significance of the Judgment
Reinforcement of Article 21
The ruling reinforces the principle that pre-trial detention cannot be punitive. When an undertrial faces years of incarceration merely because the trial is delayed, the criminal justice system risks turning oppressive.
The Supreme Court has repeatedly held that delay in trial is a valid ground for bail, even in serious offences, provided other conditions justify release.
Bail Jurisprudence in Serious Offences
Though the charges include Section 302 IPC (murder), the Court reiterated that gravity of offence alone cannot be the sole ground for denial of bail. Factors such as:
- Length of custody
- Progress of trial
- Role of the accused
- Possibility of tampering with evidence
must be weighed holistically.
Message to Trial Courts
The judgment sends a strong message to trial courts and prosecution agencies to avoid mechanical rejection of bail and ensure that constitutional rights are not eclipsed by procedural delays.
Comparison with Earlier Supreme Court Trends
This decision is consistent with recent Supreme Court rulings where bail has been granted on the ground of inordinate delay, even in cases involving serious allegations. The Court has increasingly emphasised that criminal law must balance societal interest with individual liberty.
Conclusion
The Supreme Court’s decision in Aadya Prasad Tiwari v. State of Uttar Pradesh (Criminal Appeal No. 195 of 2026) marks another important step in strengthening India’s bail jurisprudence. By prioritising the right to speedy trial and personal liberty, the Court has reaffirmed that prolonged incarceration without meaningful progress in trial is unjust and unconstitutional.
While the trial in the Mahant Narendra Giri death case will continue, the ruling ensures that justice does not become a casualty of delay, and that bail remains a tool to protect fundamental rights rather than an exception reserved for a few.
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