Bail granted on grounds of parity and charge-sheet filing despite previous rejection on merits.

The applicant, Ravi Dhimar, was arrested on July 19, 2025, in connection with Crime No. 360/2025 registered at Police Station Dongargarh for allegedly receiving illegal deposits from unknown sources in his Bandhan Bank account.

The prosecution alleged that multiple sums (ranging from ₹999 to ₹3,000) were deposited into the applicant's account between 2023 and 2024 without legal justification.

The investigation concluded with the filing of a charge-sheet against the applicant and 13 co-accused.

The applicant's first bail application (MCRC No. 9645/2025) was rejected on merits on December 11, 2025.

The applicant filed this second bail application under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, primarily citing the ground of parity.

1. Whether the applicant is entitled to regular bail based on the principle of parity with co-accused persons already granted bail by the Court.

2. Whether the completion of the investigation (filing of charge-sheet) and the duration of the applicant's pretrial detention justify the grant of bail.

The Court applied Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, governing the High Court's power to grant bail.

The substantive offences were registered under Sections 317(2), 317(4), and 317(5) of the Bharatiya Nyaya Sanhita (BNS).

The Court relied upon the judicial principle of parity, ensuring that similarly situated accused persons receive consistent treatment regarding liberty.

The Court considered the procedural status of the trial and the necessity of personal presence under Sections 209, 269, and 351 of the BNS/BNSS to ensure the integrity of the judicial process.

The Court noted that while the applicant's first bail application was dismissed on merits, a change in circumstances arose as the charge-sheet had been filed and trial proceedings were expected to be lengthy.

The pivotal factor in the Court's reasoning was the fact that two co-accused, Sachin Meshram and Aryan Namdev, whose cases were identical to the applicant's, had been granted bail in February 2026.

The State counsel conceded that the applicant's role was identical to those co-accused who were already released.

Given that the applicant had been incarcerated since July 19, 2025, and the investigation was complete, the Court determined that continued detention was unnecessary.

The Court emphasized that parity in such circumstances is a valid ground for allowing a subsequent bail application.

The Court ordered the applicant's release on bail upon furnishing a personal bond with two sureties.

The grant of bail was made subject to strict conditions: the applicant must not seek adjournments during witness testimony, must appear on all trial dates (specifically for framing of charges and recording statements under Section 351 BNSS), and faces immediate proceedings under Sections 209 and 269 of the BNS if he fails to appear or misuses his liberty.