Supreme Court Grants Bail to Bikram Kumar Sahoo in High-Profile Murder Case with Strict Trial Cooperation Conditions.


15 October 2025
The Supreme Court of India, in an order dated 15 October 2025, released Bikram Kumar Sahoo, the petitioner in a sensational case of alleged murder of Manoranjan Mahapatra on bail. The case, FIR No. 11/2023 at Police Station Nachuni, District Khurda, Odisha, carries serious offences under Sections 302 (murder), 201 (causing disappearance of evidence), and 120-B (criminal conspiracy) of the Indian Penal Code.

The charges made by the prosecution are the petitioner's illegal relationship with the wife of the deceased and a plot with her and a family member to kill Manoranjan Mahapatra. The body was said to have been disposed of in a suitcase discarded into a jungle, with CCTV footage indicating that the petitioner had bought the suitcase before the incident.


 

 

Having been in detention since his arrest on 23 January 2023, and with eighteen out of thirty-seven witnesses having been examined, the Supreme Court realized that the conclusion of the trial will take a long time. In warning against the completion of the trial prematurely to the prejudice of justice, the Court took note of the time already spent in detention and therefore allowed bail.

The petitioner was ordered to provide bail bonds to the trial court's satisfaction and to appear in person on each date of trial, to assist in trial proceedings fully. The Court reserved the right for the cancellation of bail by the State in the event of non-cooperation by the petitioner at any stage. The order did not indicate anything on the merits of the allegations.

The Special Leave Petition was disposed of accordingly, upholding the principle that bail could be granted even in grave cases if the accused is willing to cooperate and due process is safeguarded.


Indian Penal Code, 1860