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Madras High Court· 07 September 2026

Does Section 19 of the Unlawful Activities (Prevention) Act apply although the persons harboured are still under trial and are not named in the Schedule?

M.Mohammed Ali Jinnah v. Union of india Rep by its
CRL A.865/2025 · 2026:MHC:3757 · CRL A No. 865 of 2025
Coram: Justice Anita Sumanth · Justice Sunder Mohan
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Answer

Section 19 applies although the persons harboured are still under trial and are not named in the Schedule.

Yes. Section 19 applies although the persons harboured are still under trial and are not named in the Schedule. That factual position cannot enure to the benefit of the appellant at this stage, as it would, as a sequitur, defeat the purpose of Section 43D(5). (¶46, 47)

Headnote

Unlawful Activities (Prevention) Act, 1967 — ss.19, 43D(5) — Indian Penal Code, 1860 — s.212 — Constitution of India — Art.21 — Bail — Harbouring — Unlawful Activities (Prevention) Act, 1967 — s.19 — Harbouring — Shelter and concealment of identity — Held: Knowingly enabling proclaimed offenders to stay, camouflaging their true identities and arranging their phone connections prima facie amounts to harbouring. (¶45) Unlawful Activities (Prevention) Act, 1967 — s.19 — Persons not named in the Schedule — Charge not premature — Held further: That the persons harboured are still under trial and are not named in the Schedule does not defeat the charge, since that would defeat the purpose of s.43D(5). (¶46, 47) Unlawful Activities (Prevention) Act, 1967 — s.43D(5) — Constitution of India — Art.21 — Bail — Three parameters pending reference — Held further: Pending the reference, bail rests on the role prima facie attributed, the period of incarceration and the tempo of trial, read with Art.21. (¶33) Unlawful Activities (Prevention) Act, 1967 — s.43D(5) — Length of incarceration — No minimum yardstick — Held further: The length of the period served is one factor only and no minimum period is a yardstick. Appeal dismissed. (¶49, 53)

Headnote

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In the Court's own words
Paragraph 46The specific argument advanced is that Section 19 can be invoked only in the case of harbouring of terrorists and since, in this case, the POs are, as of now, only charged with commission of terrorist activities, the charge against the appellant is premature and cannot be sustained till, and only if, the primary charge against the POs is sustained finally.
Paragraph 47It is correct that the PO’s are under trial for alleged offences branding them as terrorists and as having engaged in terrorists acts. It is also correct that they are not named as terrorists under the Fourth Schedule to the Act. However, we are of the considered view that the aforesaid factual position cannot enure to the benefit of the appellant at this stage, as it would, as a sequitur, defeat the purpose of Section 43D(5).
Acts & Sections
s.19 Unlawful Activities (Prevention) Act, 1967s.43D(5) Unlawful Activities (Prevention) Act, 1967s.212 Indian Penal Code, 1860Art.21 Constitution of India

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Also decided in this judgment
Does enabling proclaimed offenders to stay and concealing their true identities amount to harbouring under Section 19 of the Unlawful Activities (Prevention) Act?Is a decision on bail under Section 43D(5) of the Unlawful Activities (Prevention) Act governed by the role prima facie attributed, the period of incarceration and the tempo of trial?Is the length of incarceration one factor only, with no minimum period serving as a yardstick for granting bail?
Plain-language answer prepared by the LexStreak Editorial Desk — verify against the judgment. Source: Madras High Court. Corrections