Advocate Bhuvnesh Kumar Goyal

Rajasthan High Court Denies Bail to Accused in Kanhaiya Lal Murder Case, Upholds Strict UAPA Bail Restrictions

Rajasthan High Court Denies Bail to Accused in Kanhaiya Lal Murder Case, Upholds Strict UAPA Bail Restrictions Jaipur, October 3, 2026: The Rajasthan High Court, Jaipur Bench, has dismissed a batch of criminal appeals filed by five accused seeking regular bail in the high-profile Kanhaiya Lal murder case investigated by the National Investigation Agency (NIA). The Division Bench of Chief Justice Sanjay K. Agrawal and Justice Sameer Jain delivered its judgment on October 3, 2026, reaffirming the stringent standards governing bail under the Unlawful Activities (Prevention) Act (UAPA). The appeals challenged orders of the Special NIA Court, Jaipur, which had rejected the bail applications of the accused. The appellants argued that they had been in custody for over four years, that the trial was likely to take considerable time and that prolonged incarceration violated their fundamental right to personal liberty under Article 21 of the Constitution. The defence also questioned the evidence linking them to the alleged conspiracy and relied on Supreme Court judgments, including Union of India v. K.A. Najeeb, to contend that constitutional protections could override statutory restrictions on bail in cases of excessive trial delays. Opposing the appeals, the NIA lawyer in jaipur argued that the accused had played specific roles in a larger criminal conspiracy and that witness statements, call detail records, video recordings and weapon recoveries supported the prosecution’s case. The agency also submitted that the trial was progressing expeditiously, with nearly 30 material witnesses already examined and the witness list reduced from approximately 180 to 89. The High Court examined the restrictions under Section 43D(5) of the UAPA and the constitutional safeguards available under Article 21. It reiterated that courts must assess whether the prosecution material establishes a prima facie case without conducting a mini-trial at the bail stage. The Bench observed that prolonged incarceration can justify bail even in UAPA cases where a timely trial is not realistically possible. However, it found that the circumstances of the present case did not warrant such relief, particularly given the progress of the trial and the specific allegations against the appellants. Consequently, the High Court upheld the orders rejecting bail and dismissed all five appeals, while clarifying that its observations would not affect the final determination of the evidence during trial. Copy of Order Bhuvnesh Kumar GoyalHigh Court Advocate in Jaipur