Bail granted for forgery citing completed investigation, no criminal antecedents, and omission from FIR.

The applicant, Devendra Sen, was arrested on November 25, 2025, in connection with Crime No. 152/2025 involving the alleged preparation of forged LIC deposit receipts

The prosecution alleged that co-accused Balbir Singh implicated the applicant, stating the applicant charged ₹5,000 to generate fake receipts which were then deleted from the computer system to conceal the fraud

The applicant contended that he was not named in the FIR, no recovery of receipts or incriminating mobile data was made from him, and the memorandum statement of the co-accused actually referred to a different individual named "Devendra Nishad"

The applicant had been in custody for over three months, and the investigation culminated in the filing of a charge-sheet

1. Whether the applicant is entitled to the grant of regular bail under Section 483 of the Bhartiya Nagarik Suraksha Sanhita, 2023, given the completion of the investigation and the nature of the evidence against him

The Court primarily applied Section 483 of the Bhartiya Nagarik Suraksha Sanhita (BNSS), 2023, regarding the High Court's power to grant regular bail

The substantive offences were registered under Sections 420, 406, 467, 468, 470, 471, 201, 120-B, and 34 of the Indian Penal Code (IPC), 1860, relating to cheating, forgery, and criminal conspiracy

The Court also incorporated procedural compliance requirements under Sections 269 (non-attendance), 84 (proclamation for person absconding), and 209 (failure to appear) of the Bharatiya Nyaya Sanhita (BNS) as conditions for the continued liberty of the applicant

The Court's reasoning centered on the balancing of the gravity of the allegations against the applicant's right to liberty during the trial. The Court observed that the applicant’s name was notably absent from the FIR and that the prosecution's case rested largely on a co-accused's statement which potentially named a different person

Crucially, the Court noted that the investigation was complete and a charge-sheet had been filed, rendering further custodial interrogation unnecessary

Additionally, the applicant’s lack of previous criminal antecedents and the fact that a co-accused had already been granted anticipatory bail weighed in favor of the applicant

Given the anticipated length of the trial, the Court determined that continued detention was not warranted

The holding clarified that the applicant must adhere to strict conditions, including: (i) attending all court dates without seeking unnecessary adjournments, and (ii) appearing in person for the opening of the case, framing of charges, and recording of statements under Section 351 of BNSS

The trial court was authorized to revoke bail if the applicant abused his liberty or failed to appear as required