Chhattisgarh High Court
Criminal LawCriminal Procedure and Evidence

Bail denied where repeated Excise Act antecedents indicate habitual offending.

DHARAM SINGH JATWAR vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: October 08, 20261 MIN READSOURCE JUDGMENT
Bail denied where repeated Excise Act antecedents indicate habitual offending.. DHARAM SINGH JATWAR vs STATE OF CHHATTISGARH. Chhattisgarh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant was arrested in connection with Crime No. 16/2026, registered under Sections 34(1)(A)(f), 34(2) and 59(A) of the Chhattisgarh Excise Act, 1915, after 21 bulk litres of liquor were allegedly seized from his house on 9 July 2026.

Source reference: para. 1–2

In his first application for regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, the applicant relied on his custody since 10 July 2026, the filing of the charge-sheet and the likely duration of trial.

Source reference: para. 3

The State opposed bail, citing six prior Excise Act cases from 2022 to 2026, three of which remained pending.

Source reference: para. 4
02

Issues

1. Whether the applicant should be released on regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, despite the alleged seizure of 21 bulk litres of liquor and his prior similar cases.

Source reference: para. 1–6
03

Law Applied

The application was made under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, which provides the basis for the Court’s consideration of regular bail.

Source reference: para. 1

The alleged offences were under Sections 34(1)(A)(f), 34(2) and 59(A) of the Chhattisgarh Excise Act, 1915.

Source reference: para. 1

The Court’s stated basis for deciding the application was its assessment of the alleged quantity and nature of the contraband and the applicant’s antecedents; it cited no separate precedent or further legal test.

Source reference: para. 6
04

Reasoning

The Court acknowledged that the charge-sheet had been filed, but considered the alleged seizure of 21 bulk litres alongside the applicant’s six prior cases of a similar nature, including three still pending.

Source reference: para. 6

It treated those antecedents as indicating that the applicant was a habitual offender and concluded that the quantity and nature of the contraband, particularly when considered with the antecedents, weighed against release on bail.

Source reference: para. 6
05

Holding

The Court rejected the applicant’s first regular-bail application in Crime No. 16/2026 for offences under Sections 34(1)(A)(f), 34(2) and 59(A) of the Chhattisgarh Excise Act, 1915.
06

Acts & Sections Cited

1 provisions across 1 statute referred to in this judgment. Each provision opens on LawLens.

Bharatiya Nagarik Suraksha Sanhita, 20231

Chhattisgarh High Court

Original Court PDF

DHARAM SINGH JATWARvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · October 08, 2026

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