Anticipatory bail granted on grounds of parity and lack of active involvement in alleged transaction.

The applicant, Neena Jain, sought anticipatory bail regarding Crime No. 0020/2026 registered at Police Station Saraswati Nagar, Raipur.

The prosecution alleged that the accused induced a complainant company to invest approximately ₹11.51 crores in an immovable property transaction by falsely representing the property as free from encumbrances.

It is alleged that the property was actually mortgaged and subject to recovery proceedings before the Debt Recovery Tribunal.

The applicant contended she held only a managerial role, had no involvement in the negotiations or payments, and claimed false implication.

She further sought parity with co-accused persons who had already been granted bail.

1. Whether the applicant is entitled to the protection of anticipatory bail under Section 482 of the Bhartiya Nagarik Suraksha Sanhita, 2023, based on the principle of parity and the nature of the allegations.

Section 482 of the Bhartiya Nagarik Suraksha Sanhita (BNSS), 2023, which governs the High Court's power to grant anticipatory bail.

Sections 318(4) (Cheating), 338 (Forgery), 336(3) (Punishment for Forgery), and 61(2) (Criminal Conspiracy) of the Bhartiya Nyaya Sanhita (BNS), 2023.

The court relied on the legal principle of parity, ensuring that similarly situated accused persons receive consistent judicial treatment regarding liberty.

The court evaluated the facts and the nature of the dispute, noting the absence of any prior criminal antecedents for the applicant.

The court specifically observed that two co-accused, Vinod Bajoria (MCRCA No. 167 of 2026) and Pritam Tekriwal (MCRCA No. 1598 of 2026), had already been granted anticipatory bail by the same High Court.

Taking into account the applicant’s assertion that she was a mere manager without decision-making authority over the sale agreement and the fact that the dispute arose from a commercial transaction, the court found that the applicant was "similarly situated" to the already-released co-accused.

Consequently, the court determined that the benefit of parity was applicable without delving into the detailed merits of the evidence.

The court held that in the event of arrest, Neena Jain shall be released upon executing a personal bond and providing one local surety, subject to conditions including non-interference with witnesses, regular appearances before the trial court, and a prohibition against committing similar future offences.