Chhattisgarh High Court

Bail granted for intermediate quantity of Ganja where applicants lacked criminal antecedents and charge-sheet was filed.

RAJKUMAR THAKUR vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: April 25, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicants, Rajkumar Thakur and Sarju Shrivas, were arrested on 30.11.2025 following a police search based on secret information regarding illegal contraband

Source reference: p. 2, para. 2

The police seized 10 kg of Ganja from their joint possession at N.H. 53 Road, village Rehatikhol

Source reference: p. 2, para. 2

The applicants were charged under Section 20(B) II B of the Narcotic Drugs and Psychotropic Substances (NDPS) Act.

Source reference: p. 1, para. 1

This First Bail Application was filed under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, seeking regular bail after the filing of the charge-sheet

Source reference: p. 1, para. 1; p. 2, para. 3
02

Issues

1. Whether the applicants are entitled to regular bail considering the quantity of contraband seized and their duration of incarceration

Source reference: p. 3, para. 6
03

Law Applied

The Court applied the provisions of the Narcotic Drugs and Psychotropic Substances (NDPS) Act, specifically Section 20(B) II B for possession of intermediate quantity

Source reference: p. 2, para. 1

It assessed the "rigors of Section 37 of the NDPS Act," which imposes stringent conditions for bail in cases involving "commercial quantities" (defined as more than 20 kgs for Ganja)

Source reference: p. 2, para. 3

Procedurally, the application was governed by Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023

Source reference: p. 1, para. 1

the court noted potential penalties under Sections 209 and 269 of the Bharatiya Nyaya Sanhita (BNS) for violations of bail conditions

Source reference: p. 4, para. 7
04

Reasoning

The Court observed that the 10 kg of Ganja seized from the applicants constitutes an "intermediate quantity," which is significantly less than the 20 kg threshold required to trigger the restrictive bail conditions of Section 37 of the NDPS Act

Source reference: p. 2, para. 3; p. 3, para. 6

The Hon’ble Chief Justice noted that the charge-sheet had already been filed and that the applicants had no prior criminal antecedents

Source reference: p. 2, para. 4; p. 3, para. 6

Furthermore, the court considered the period of detention (since 30.11.2025) and the likelihood that the trial would not conclude in the near future.

Source reference: p. 3, para. 6

Given these factors—possession of sub-commercial quantity, lack of antecedents, and the stage of investigation—the court determined that continued custody was not warranted

Source reference: p. 3, para. 6
05

Holding

The Court allowed the bail application and ordered the release of Rajkumar Thakur and Sarju Shrivas upon furnishing personal bonds and two sureties each to the satisfaction of the trial court

The holding was conditional upon the applicants not seeking unnecessary adjournments, appearing on all fixed dates, and complying with procedural requirements under Sections 84, 209, 269, and 351 of the BNSS/BNS

Source reference: p. 4, para. 7

The Court directed immediate compliance and notification to the trial court

Source reference: p. 4, para. 8
Chhattisgarh High Court

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RAJKUMAR THAKURvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · April 25, 2026

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