Anticipatory bail granted where injuries are simple in nature despite existence of a criminal antecedent.

The applicants sought anticipatory bail regarding Crime No. 25/2026 registered at Police Station Sanna, District Jashpur.

On March 4, 2026, the complainant alleged that the applicants arrived at her house in a Bolero vehicle, verbally abused her husband, and assaulted him with hands, fists, and a wooden stick (danda), causing injuries to his head and face.

It was further alleged that Applicant No. 2 slapped a witness and snatched her mobile phone.

The applicants contended they were falsely implicated; Applicant No. 1 is handicapped and claimed the charges were retaliation for a complaint he filed regarding fraudulent names in a 2002 survey list.

The State noted that while the applicants have one criminal antecedent, the victim's injuries were simple in nature.

1. Whether the applicants are entitled to the grant of anticipatory bail under Section 482 of the Bhartiya Nagarik Suraksha Sanhita, 2023, considering the nature of the injuries and the circumstances of the case.

Section 482 of the Bhartiya Nagarik Suraksha Sanhita (BNSS), 2023, which governs the directions for grant of bail to persons apprehending arrest.

Sections 296 (obscene acts/songs), 351(2) (criminal intimidation), 115(2) (voluntarily causing hurt), 3(5) (joint liability), 309(4) (robbery/extortion-related), and 331(6) (house-trespass/hurt) of the BNS, 2023.

The Court weighed the prosecution's allegations against the medical and procedural realities of the case. Although the State opposed bail citing a criminal antecedent, it conceded that the injuries sustained by the victim were medically classified as "simple in nature".

The Court observed that the trial was likely to take a considerable amount of time to conclude.

By balancing the handicap status of Applicant No. 1 and the non-grievous nature of the injuries against the need for judicial presence, the Court determined that custodial interrogation was not necessitated and the applicants' liberty could be secured through stringent bail conditions.

It directed that in the event of arrest, Shrinath Sahni and Deepak Sahni be released on a personal bond and one surety each, subject to conditions including non-interference with witnesses, regular appearances, Aadhaar verification, and a mandate not to involve themselves in similar future offenses.