Madhya Pradesh High Court

Absconding for an extended period disentitles an accused from claiming bail on the ground of parity.

Ramdev Rathore vs The State Of Madhya Pradesh

Madhya Pradesh High CourtJUDGMENT: July 07, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant, an agent/director of Shrishti Ware Industries Ltd., was accused of inducing investors to deposit funds with the promise of doubling their money within five years, which the company subsequently failed to return

Source reference: para 2

A case was registered in 2016 under Sections 420, 467, 468, 471, and 120-B of the IPC and Section 6(1) of the Madhya Pradesh Nikshepakon Ke Hiton Ka Sanrakshan Adhiniyam, 2000

Source reference: para 2

The applicant remained absconding since 2016, through the dismissal of an anticipatory bail plea in 2020, and finally surrendered on September 4, 2025

Source reference: para 3, 6

This is the second regular bail application; the first was withdrawn in February 2026

Source reference: para 1
02

Issues

1. Whether the applicant is entitled to regular bail on the ground of parity with co-accused persons who were granted conditional bail upon depositing alleged defalcated amounts

Source reference: para 3, 6

2. Whether the applicant’s long period of abscondence (2016–2025) disentitles him to discretionary relief under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023

Source reference: para 6, 7
03

Law Applied

Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (analogous to Section 439 CrPC) regarding regular bail.

Source reference: para 1, 2

Sections 420 (Cheating), 467, 468, 471 (Forgery), and 120-B (Criminal Conspiracy) of the IPC, alongside Section 6(1) of the Madhya Pradesh Nikshepakon Ke Hiton Ka Sanrakshan Adhiniyam, 2000, which protects the interests of depositors in financial establishments

Source reference: para 1, 2

The principle that "parity" is not an absolute right if the conduct of the accused, specifically long-term abscondence, distinguishes their case from others

Source reference: para 6, 7
04

Reasoning

The applicant argued for parity, noting that he was ready to deposit the ₹8,00,000 attributed to him and citing the bail granted to co-accused Santosh Kumar Rathore by the Supreme Court

Source reference: para 3

The Court rejected the parity argument, observing that the applicant had been evading the law since 2016

Source reference: para 6

The Court reasoned that the applicant's status as an absconder for nearly nine years distinguished his circumstances from those who were granted bail earlier in 2020

Source reference: para 6, 7

The court found that the case diary contained sufficient prima facie material indicating the applicant’s active involvement in the fraudulent scheme

Source reference: para 7
05

Holding

The Court answered the issues in the negative, holding that the applicant is not entitled to bail at this stage due to the gravity of the offence and his prolonged abscondence

The application for regular bail was dismissed

Source reference: para 8
Madhya Pradesh High Court

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Ramdev RathorevsThe State Of Madhya Pradesh

Madhya Pradesh High Court · July 07, 2026

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