Chhattisgarh High Court

Bail denied for sexual exploitation and SC/ST Act offenses pending investigation and filing of charge-sheet.

CHANDRABHAN YADAV vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: March 23, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Appellant filed an appeal under Section 14A(2) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (SC/ST Act) following his arrest in connection with Crime No. 11/2026.

Source reference: para. 1

The complainant alleged that the Appellant, despite knowing her caste, induced her with a promise of marriage in April 2025 and established physical relations by deceit.

Source reference: para. 2

She further alleged that the Appellant sexually exploited her until January 2026 by threatening to make obscene photographs and videos viral.

Source reference: para. 2

The Appellant was arrested on February 3, 2026, and charged under Section 64(2)(m) of the Bharatiya Nyaya Sanhita (BNS) and Sections 3(1)(2) and 3(2)(v)(a) of the SC/ST Act.

Source reference: paras. 1, 3

The Appellant contended that there was an unexplained 10-month delay in the FIR and that the complainant was a married major woman.

Source reference: para. 3
02

Issues

Whether the Appellant is entitled to the grant of bail under Section 14A(2) of the SC/ST Act in light of the allegations and the current stage of the investigation.

Source reference: para. 6
03

Law Applied

The Court applied Section 14A(2) of the SC/ST Act, 1989, which provides the statutory framework for appeals against the grant or refusal of bail.

Source reference: para. 1

Substantively, the Court considered Section 64(2)(m) of the BNS regarding sexual intercourse by deceitful means and Sections 3(1)(2) and 3(2)(v)(a) of the SC/ST Act, which penalize atrocities committed against members of Scheduled Castes or Scheduled Tribes.

Source reference: para. 1
04

Reasoning

The Court weighed the Appellant’s arguments regarding his innocence, the delay in the FIR, and the lack of criminal antecedents against the State’s opposition.

Source reference: paras. 3-4

The State Counsel and the victim contended that the Appellant used intoxicating substances to establish relations and recorded obscene media for blackmail.

Source reference: paras. 4-5

In its reasoning, the Court focused on the procedural status of the case, specifically noting that the investigation remained ongoing and the charge-sheet had not yet been filed.

Source reference: para. 6

The Court determined that due to the gravity of the allegations and the fact that the investigation was in its nascent stages, it was not inclined to exercise its discretion to grant bail at this time.

Source reference: para. 6
05

Holding

The Court rejected the appeal and refused to grant bail to the Appellant.

The Court held that the ongoing nature of the investigation and the fact that the charge-sheet was pending were sufficient grounds to deny the request for release at this stage.

Source reference: para. 6
Chhattisgarh High Court

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CHANDRABHAN YADAVvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · March 23, 2026

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