Chhattisgarh High Court
Criminal LawCriminal Procedure and Evidence

A pending criminal antecedent does not preclude bail after charge-sheet filing where trial will take time.

DHANIRAM KHARE vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: October 14, 20262 MIN READSOURCE JUDGMENT
A pending criminal antecedent does not preclude bail after charge-sheet filing where trial will take time.. DHANIRAM KHARE vs STATE OF CHHATTISGARH. Chhattisgarh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant was arrested in connection with Crime No. 295/2026, registered at Kawardha Police Station under Section 6 of the Chhattisgarh Gambling (Prohibition) Act, 2022. Police allegedly seized a sattapati ledger and ₹780 from him after receiving secret information.

Source reference: para. 2

The applicant had three criminal antecedents: two cases had been disposed of, while a 2024 case under Sections 201 and 420 of the IPC remained pending.

Source reference: para. 3

The State opposed bail, citing the applicant’s antecedents, including two cases said to be of a similar nature.

Source reference: para. 4

The charge-sheet had been filed, and the applicant had been in custody since 29 July 2026.

Source reference: para. 3
02

Issues

Whether the applicant should be released on regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, despite his criminal antecedents.

Source reference: paras. 1, 3–6
03

Law Applied

Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, provides the basis for the application for regular bail.

Source reference: para. 1

The alleged offence was under Section 6 of the Chhattisgarh Gambling (Prohibition) Act, 2022.

Source reference: para. 1

The Court identified no precedent or further legal test; it considered the case circumstances, including the completion of investigation, custody, likely time to conclude trial, and the applicant’s antecedents.

Source reference: para. 6
04

Reasoning

Although the applicant had one pending antecedent from 2024, the Court considered that the investigation was complete and the charge-sheet had been filed, that he had been in judicial custody since 29 July 2026, and that trial was likely to take time.

Source reference: para. 6

On those circumstances, and without commenting on the merits, the Court found it appropriate to grant regular bail.

Source reference: para. 6
05

Holding

The Court allowed the bail application.

It directed that the applicant be released upon furnishing a personal bond of ₹50,000 with one surety in the like amount to the satisfaction of the trial Court, subject to conditions prohibiting interference with witnesses or the fair and expeditious trial and requiring his appearance on every trial date.

Source reference: para. 7

The observations were confined to the bail application, and the trial Court was to decide the case on its merits.

Source reference: para. 8
06

Acts & Sections Cited

3 provisions across 2 statutes referred to in this judgment. Each provision opens on LawLens.

Bharatiya Nagarik Suraksha Sanhita, 20231

Indian Penal Code, 18602

Chhattisgarh High Court

Original Court PDF

DHANIRAM KHAREvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · October 14, 2026

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