Chhattisgarh High Court

Absence of injuries and completion of investigation warrant grant of bail despite prior criminal antecedents.

ASHISH KUMAR DHRUV @ RINKU vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: April 28, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant sought regular bail following his arrest on December 17, 2025, in connection with Crime No. 180/2025.

Source reference: para 1, 2

The prosecution alleged that on September 2, 2025, the applicant and co-accused, under the influence of alcohol, wrongfully restrained the complainant, demanded money, used abusive language, and threatened him with a sharp weapon and property damage.

Source reference: para 2

A charge-sheet was filed on February 12, 2026, for offences under Sections 296, 115(2), 351(3), 119, and 3(5) of the Bharatiya Nyaya Sanhita (BNS), 2023.

Source reference: para 2

The applicant contended he was falsely implicated, cited the bail granted to similarly situated co-accused, and noted his status as a 22-year-old sole breadwinner.

Source reference: para 3
02

Issues

1. Whether the applicant is entitled to the grant of regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, considering the nature of allegations and his period of incarceration.

Source reference: para 1, 6
03

Law Applied

The court exercised its discretionary power under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, regarding the grant of regular bail.

Source reference: para 1

The court also applied the principle that the absence of physical injury and the completion of the investigation (filing of charge-sheet) are significant factors in favoring the liberty of the accused pending trial.

Source reference: para 6

Sections 296 (Obscene acts/songs), 115(2) (Voluntarily causing hurt), 351(3) (Criminal intimidation), 119 (Punishment for criminal intimidation), and 3(5) (Joint liability) of the Bharatiya Nyaya Sanhita (BNS), 2023.

Source reference: para 1
04

Reasoning

The Court weighed the State's concerns regarding the applicant’s two criminal antecedents and the aggressive nature of the alleged acts against the mitigating factors presented by the defense.

Source reference: para 4

It specifically noted that despite allegations of assault, no external or internal injuries were reported, which significantly reduced the gravity of the "assault" charge.

Source reference: para 6

The Court observed that one of the applicant's two previous cases had been compromised, leaving only one pending matter.

Source reference: para 6

Furthermore, as the charge-sheet had already been submitted and the applicant had been in custody since December 2025, the Court determined that continued detention was unnecessary as the trial would likely take considerable time.

Source reference: para 6
05

Holding

The lack of injury and completion of the investigation justified the release.

The Court allowed the bail application, granting the applicant regular bail. The applicant was ordered to be released upon furnishing a personal bond with two sureties, subject to strict conditions: he must not seek unnecessary adjournments, must appear personally on key trial dates (framing of charges, Section 351 BNSS statements), and must comply with procedures under Section 269 and 209 of the BNS in case of default.

Source reference: para 7
Chhattisgarh High Court

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ASHISH KUMAR DHRUV @ RINKUvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · April 28, 2026

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