Headnotes — Gounipalli Adi Narayana & Anr. v. State of Andhra Pradesh & Anr.
Crl.P. Nos. 7332 & 7333 of 2026 — Dr. Y. Lakshmana Rao, J. — 25.08.2026
2026:APHC:34861
Bail — Investigation at nascent stage — Nature of injuries not yet ascertained:
Where the de-facto complainant alleged that Accused Nos.1 and 2 attacked him with a sickle and caused grievous injuries, and the wound certificate had not yet been received to ascertain the nature of the injuries, the High Court declined to grant bail at that stage, particularly when the investigation was still pending. [Para 7]Bail — Serious allegation of assault — Pending investigation:
The pendency of investigation, coupled with the allegation of an attack with a sickle causing grievous injuries and the absence of the wound certificate, was considered sufficient to decline bail to Accused Nos.1 and 2. [Para 7]Pre-arrest bail — Accused No.3 — Distinct consideration:
Though bail was declined to Accused Nos.1 and 2, the Court considered the nature of the allegations against Accused No.3 separately and, having regard to the facts and circumstances, found it appropriate to grant her pre-arrest bail subject to stringent conditions. [Para 8]Anticipatory bail — Conditions:
Grant of pre-arrest bail was made conditional upon execution of a bond of Rs.10,000/- with two sureties each for the like sum, to the satisfaction of the arresting police officials. [Para 9(i)]Anticipatory bail — Cooperation with investigation:
The beneficiary of pre-arrest bail must make herself available for investigation whenever required by the Investigating Officer. [Para 9(ii)]Anticipatory bail — Periodic appearance before police:
Accused No.3 was directed to appear before the concerned Station House Officer every Saturday between 10:00 a.m. and 5:00 p.m., once a week, until filing of the charge-sheet. [Para 9(iii)]Anticipatory bail — Restriction on travel:
Accused No.3 was prohibited from leaving the territorial limits of Andhra Pradesh without the express permission of the concerned Station House Officer. [Para 9(iv)]Anticipatory bail — Protection of witnesses/investigation:
Accused No.3 was restrained from directly or indirectly making any inducement, threat or promise to any person acquainted with the facts of the case so as to dissuade such person from disclosing those facts to the Court. [Para 9(v)]Anticipatory bail — Passport surrender:
Accused No.3 was directed to surrender her passport, if any, to the Investigating Officer. If she claimed that she had no passport, she was required to submit an affidavit to that effect. [Para 9(vi)]
Core ratio
Where the nature of injuries alleged to have been caused in an assault is yet to be ascertained because the wound certificate is pending, and investigation is still underway, the Court may decline regular bail at that stage. However, the entitlement to pre-arrest bail of a co-accused must be independently considered having regard to the nature of the allegations against that accused, and anticipatory bail may be granted subject to stringent conditions. [Paras 7–9]
Final Order
Crl.P.No.7332 of 2026 — Dismissed insofar as Accused Nos.1 and 2 are concerned.
Crl.P.No.7333 of 2026 — Allowed and Accused No.3 granted pre-arrest bail subject to the six conditions stipulated by the Court.
The order does not lay down a general proposition that pendency of investigation alone bars bail; the decision turned on the pending wound certificate, allegation of grievous injury by use of a sickle, and the stage of investigation. [Para 7]
