Chhattisgarh High Court

Anticipatory bail granted where sole evidence is uncorroborated memorandum statement of co-accused without supporting digital evidence.

PRAKASH PANJWANI vs THE STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: March 16, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

On January 6, 2026, police conducted a raid in Vyapar Vihar, Bilaspur, based on a tip regarding online cricket gambling.

Source reference: para. 2

They arrested Ayush Agrawal, whose interrogation and seized mobile phone data allegedly implicated the applicant, Prakash Panjwani, as an associate in the gambling syndicate

Source reference: para. 2

WhatsApp chats were recovered from co-accused Ayush and another individual, Shanky Saluja

Source reference: para. 2

The applicant, apprehending arrest for offenses under Section 7(2) of the Chhattisgarh Gambling (Prohibition) Act, 2022, and Section 112 of the Bharatiya Nyaya Sanhita (BNS), 2023, moved the High Court for anticipatory bail after being named in the memorandum statement of the co-accused

Source reference: para. 1-2
02

Issues

Whether the applicant is entitled to anticipatory bail when the primary evidence against him is a memorandum statement of a co-accused, unsupported by corroborating digital evidence

Source reference: para. 3, 7
03

Law Applied

Section 7(2) of The Chhattisgarh Gambling (Prohibition) Act, 2022, and Section 112 of the BNS, 2023

Source reference: para. 1

the absence of incriminating material beyond a co-accused's statement and the lack of criminal antecedents are significant factors for granting relief

Source reference: para. 7
04

Reasoning

The Court observed that the prosecution's case against the applicant relied almost exclusively on the memorandum statement of co-accused Ayush Agrawal

Source reference: para. 7

Upon reviewing the Cyber Cell report dated March 12, 2026, the Court found that the applicant's name did not appear in any WhatsApp chats retrieved from the arrested co-accused; instead, the chats referred to a "Rohit Panjwani"

Source reference: para. 5, 7

The Court further noted that the applicant had no prior criminal record and that the other co-accused, Ayush Agrawal and Shanky Saluja, had already been released on regular bail by the Sessions Court

Source reference: para. 7

Since no direct incriminating material or digital trail connected the applicant to the online gambling syndicate at this stage, the Court determined that custodial interrogation was not warranted

Source reference: para. 7
05

Holding

The Court allowed the application and granted anticipatory bail to the applicant

It held that in the event of arrest, the applicant shall be released on a personal bond of Rs. 25,000 with one surety of the like sum

Source reference: para. 8

The relief was made subject to conditions, including that the applicant must cooperate with the interrogation as required, refrain from influencing witnesses, and appear before the trial court on all scheduled dates

Source reference: para. 8
Chhattisgarh High Court

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PRAKASH PANJWANIvsTHE STATE OF CHHATTISGARH

Chhattisgarh High Court · March 16, 2026

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