An adult accused cannot claim bail parity solely with a juvenile co-accused.

The applicant, Jatin Asi Yadav, was arrested in connection with Crime No. 649/2025 registered at Police Station Ambikapur Dehat (Gandhinagar), District Surguja, for alleged offences under Sections 318(4), 317(4), 111 and 61(2) of the Bharatiya Nyaya Sanhita, 2023 (“BNS”).

The prosecution alleged that co-accused Anish Giri induced a CSC-centre operator to receive ₹99,999 through his QR code from the bank account of Gurmeet Singh.

The amount was allegedly withdrawn in cash and shared among members of a cyber-fraud network using mule bank accounts.

The applicant’s alleged role emerged during investigation; he was accused of providing his bank account, QR code and ATM facility for receiving and withdrawing fraudulently obtained money and sharing the proceeds with other accused persons.

A supplementary charge-sheet was filed against him on 19 July 2026.

The applicant claimed false implication, absence of any overt act in the FIR, lack of knowledge of the fraudulent source of the money, completion of investigation, absence of criminal antecedents, and parity with a juvenile co-accused who had been granted bail.

The State opposed bail on the basis of the seriousness of the cyber-fraud allegations, the material collected during investigation, and the rejection of bail applications filed by several co-accused.

Whether the applicant was entitled to regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, in view of the allegations and material connecting him with the alleged cyber-fraud scheme.

Whether the applicant could claim parity with the juvenile co-accused who had been granted bail.

Whether the filing of the supplementary charge-sheet, the applicant’s age, absence of criminal antecedents, and completion of investigation justified his release on bail.

The Court applied Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, governing the High Court’s power to grant regular bail.

It considered the allegations under Sections 318(4), 317(4), 111 and 61(2) of the BNS, 2023.

The governing bail principle required the Court to assess the nature and seriousness of the allegations, the material collected during investigation, and the prima facie role attributed to the accused.

The principle of parity was also considered, but parity is not automatic where the co-accused’s bail was granted on a materially different basis, including juvenile status.

The Court found that the applicant’s alleged role could not be disregarded at the bail stage.

The material collected during investigation prima facie indicated that he had provided his bank account, QR code and ATM facility for receiving and withdrawing money allegedly obtained through cyber fraud, followed by sharing of the proceeds with other accused persons.

Although the applicant relied on the absence of any specific allegation in the original complaint, the Court considered the subsequent investigative material relevant for determining his prima facie involvement.

The filing of the charge-sheet did not, by itself, entitle him to bail.

The Court rejected the parity argument because the co-accused had been granted bail in view of his status as a juvenile, which materially distinguished his case from that of the applicant.

The rejection of bail applications filed by several other co-accused was also treated as a relevant circumstance.

The applicant’s first application under Section 483 of the BNSS was accordingly rejected.

The trial Court was directed to proceed with and conclude the trial expeditiously, and a certified copy of the order was directed to be sent to the trial Court for information and compliance.