Facts
Komal Sahu consumed poison on 17 October 2025 and died during treatment on 21 November 2025.
Source reference: para. 2Following a morgue inquiry, Crime No. 130/2026 was registered at Kotwali Police Station, Rajnandgaon, for alleged offences under Sections 318(4), 108 and 3(5) of the Bharatiya Nyaya Sanhita, 2023.
Source reference: para. 2The applicant was implicated on the basis of a suicide note.
Source reference: para. 2He submitted that the deceased had collected money for investment, including money from the applicant, and that the applicant had pursued a cheque issued by the deceased under Section 138 of the Negotiable Instruments Act.
Source reference: para. 3He also relied on the grant of bail to a co-accused.
Source reference: para. 3The State opposed the application, referring to the suicide note and the deceased’s alleged repayment to the applicant, but did not dispute that the co-accused had been granted bail.
Source reference: para. 4The applicant sought anticipatory bail under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023.
Source reference: para. 1Issues
1. Whether the applicant should be granted anticipatory bail in connection with Crime No. 130/2026
Source reference: paras. 1, 62. Whether the grant of bail to the co-accused, considered with the circumstances and allegations, supported granting the applicant anticipatory bail
Source reference: paras. 3–6Law Applied
Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023, provides for a direction for release on bail in the event of arrest.
Source reference: para. 1The alleged offences were under Sections 318(4), 108 and 3(5) of the Bharatiya Nyaya Sanhita, 2023.
Source reference: para. 1The Court identified no particular precedent or further legal test; it considered the facts, nature of the allegations and parity with the bailed co-accused, without expressing any view on the merits.
Source reference: para. 6Reasoning
The Court considered the applicant’s account that the money was given to the deceased for investment and was being pursued through a cheque-dishonour proceeding, alongside the State’s reliance on the suicide note and the alleged repayment.
Source reference: paras. 3–4It also took into account that a co-accused had been granted bail.
Source reference: para. 6On consideration of the circumstances and the nature of the allegations, the Court found it appropriate to grant anticipatory bail without commenting on the merits.
Source reference: para. 6Holding
The application was allowed.
The Court directed that, in the event of arrest in Crime No. 130/2026, the applicant be released on anticipatory bail on executing a personal bond of ₹25,000 with one surety for the like sum.
Source reference: para. 7The applicant must be available for interrogation when required, refrain from influencing persons acquainted with the case or prejudicing a fair and expeditious trial, and appear before the trial Court on each date fixed until the trial’s disposal.
Source reference: para. 7Acts & Sections Cited
5 provisions across 3 statutes referred to in this judgment. Each provision opens on LawLens.
Bharatiya Nagarik Suraksha Sanhita, 20231
Bharatiya Nyaya Sanhita, 20233
Negotiable Instruments Act, 18811
Original Court PDF
MILAP SAHUvsSTATE OF CHHATTISGARH
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