Anticipatory bail may be granted absent specific material showing conscious participation in alleged document forgery.

The applicant sought anticipatory bail under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023, in connection with Crime No. 116/2026, registered for alleged offences involving forged documents and fraudulent sale deeds relating to land at Village Kaimaha, Chhatarpur.

The applicant, an authorised stamp vendor, maintained that he had no knowledge of the alleged fraud, had approached the police and filed a private complaint before the JMFC concerning the transaction, and had not prepared or forged any documents.

The State opposed bail, submitting that the applicant’s complaints did not establish innocence and that the transaction documents required investigation.

Whether the applicant had made out a case for anticipatory bail in light of the allegations and material available on record.

Whether the applicant’s alleged role and the nature of the evidence justified requiring his custodial interrogation.

The application was considered under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023, which provides for a direction for grant of bail to a person apprehending arrest.

The alleged offences were under Sections 340(2), 336(3), 338, 318(4), 319(2), 61(2) and 3(5) of the Bharatiya Nyaya Sanhita, 2023.

The Court also directed compliance with conditions it identified as those under Section 480(2) and sub-section (3) of Section 480 of the Cr.P.C.

The Court found that, although the allegations concerned the preparation and use of forged documents to execute fraudulent sale deeds, no specific material had been brought to its notice showing that the applicant had fabricated documents or impersonated the landowners.

It also considered the applicant’s claim that he had approached the police and filed a private complaint after allegedly discovering the forgery.

On the material before it, the Court concluded that the applicant had made out a case for anticipatory bail, without expressing an opinion on the merits.

The applicant must remain available for interrogation, refrain from influencing the complainant or witnesses, not leave India without prior permission, and comply with the other stated bail conditions.