Bail granted for simple injuries upon completion of investigation despite prior criminal history ending in acquittal.

On January 1, 2026, at approximately 12:30 AM, the complainant, Suresh Yadav, alleged that the applicant, Rahul @ Bajrangi Sahu, approached him outside his house, used abusive language, threatened his life, and assaulted him with a sharp object.

The applicant was arrested on January 6, 2026.

Following an investigation, the police filed a charge sheet for offenses involving criminal intimidation and assault with dangerous weapons.

The applicant filed this first bail application under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), contending that the dispute was minor, the injuries were simple, and he had already been acquitted in his previous criminal cases.

1. Whether the applicant is entitled to regular bail under Section 483 of the BNSS considering the nature of the injuries, the filing of the charge sheet, and the applicant's past criminal record.

The court primarily applied Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), which empowers the High Court to grant regular bail.

The substantive offenses charged were under the Bharatiya Nyaya Sanhita (BNS), specifically Sections 296 (obscene acts/words), 115(2) (voluntarily causing hurt), 351(2) (criminal intimidation), and 118(1) (voluntarily causing hurt by dangerous weapons or means), as well as Sections 25 and 27 of the Arms Act.

The court also considered the principle that prolonged detention and the filing of a charge sheet are relevant factors in bail adjudication, alongside the legal standing of criminal antecedents where the accused resulted in an acquittal.

The court evaluated the merits of the bail application by examining the medical evidence and procedural status of the case.

It observed that the MLC report did not characterize the injuries as grievous; rather, they appeared simple in nature, as evidenced by the complainant’s discharge from the hospital within one day.

The court noted that since the charge sheet had already been filed and the applicant had been in custody since January 6, 2026, further detention was not necessitated for investigation.

Regarding the State’s objection concerning the applicant’s three criminal antecedents, the court observed that the applicant had been acquitted in all those instances, thus neutralizing the weight of those past records against him.

Finally, the court weighed the likelihood of a protracted trial against the applicant’s right to liberty and determined that bail was appropriate provided strict conditions were imposed to prevent the abuse of liberty.

The court allowed the bail application and directed the release of the applicant on a personal bond with two sureties.

The relief was granted subject to several conditions: the applicant must not seek adjournments when witnesses are present, must appear personally at specific trial stages (such as framing of charges and recording of statements under Section 351 of BNSS), and must comply with procedures under Sections 209 and 269 of the BNS/BNSS if he defaults on court appearances.