Anticipatory bail granted where initial minor roadside scuffle was subsequently escalated to attempt to murder.

The applicant, Bhanu Patel, filed a first anticipatory bail application regarding Crime No. 533/2025 registered at P.S. Vijaynagar, Jabalpur

The prosecution alleged that on December 14, 2025, a road rage incident occurred involving a scuffle and verbal abuse

Initially, the FIR did not mention a wooden stick or an attempt to run over the complainant with a car. However, after a co-accused (Sachin) was granted bail, the complainant further alleged that the applicant (driving a Creta) attempted to run him over, leading to the addition of Section 109 of the BNS

The applicant contended he was falsely implicated and that a minor altercation was being escalated into an attempt to murder

Whether the applicant is entitled to the grant of anticipatory bail under Section 482 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, based on the nature of allegations and lack of criminal antecedents

Section 482 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 (the successor to Section 438 of the Cr.P.C.), which governs the grant of bail to persons apprehending arrest

Substantive offences under Sections 296 (B), 115(2), 351(3), 117(2), and 109 read with Section 3/5 of the Bharatiya Nyaya Sanhita (BNS), 2023

Established principles of bail, including the assessment of the applicant's socio-economic status, the necessity of custodial interrogation, and the likelihood of the accused fleeing from justice or tampering with evidence

The Court observed that the initial FIR lodged by the complainant did not contain the more grave allegations of attempting to run him over; these were added subsequently after a co-accused received bail, lending prima-facie substance to the applicant’s claim of exaggerated accusations

The Court found that custodial interrogation was not necessary for the investigation and that there was no evidence suggesting the applicant would flee or influence witnesses

The Court highlighted that incarceration on potentially false accusations would cause undue social disrepute and hardship

The Court directed that in the event of arrest, Bhanu Patel shall be released upon furnishing a personal bond of Rs. 50,000 with one solvent surety of the same amount subject to conditions including non-involvement in similar offences, non-interference with evidence or witnesses, and compliance with Section 346 of the BNSS