Bail granted on parity and charge-sheet filing despite the applicant's prior criminal antecedents.

The applicant, Satyam Shukla, filed his first bail application following his arrest on December 13, 2025, in connection with Crime No. 327/2025.

The prosecution alleged that on December 12, 2025, the applicant and two unknown persons committed the loot of a Honda Shine motorcycle by threatening the complainant with a knife.

The applicant contended he was falsely implicated based on suspicion, as no seizure of the motorcycle or weapon was made from his possession.

The State opposed bail, noting that while one NDPS case against the applicant was disposed of, four other criminal cases under the IPC remain pending.

The applicant sought parity with a co-accused, Tarun Baghel, who was granted bail in February 2026.

Whether the applicant is entitled to regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS) based on the principle of parity and the stage of the investigation?

Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, which governs the grant of regular bail.

Sections 309(4) (robbery/loot) and 3(5) (acts done by several persons in furtherance of common intention) of the Bharatiya Nyaya Sanhita (BNS).

Sections 25 and 27 of the Arms Act.

Principle of parity, ensuring consistency in judicial discretion when a similarly situated co-accused has been granted relief.

The court weighed the gravity of the allegations—specifically the use of a knife during the robbery—against the applicant’s period of detention and the progress of the legal proceedings.

While acknowledging the applicant's five criminal antecedents, the court observed that the NDPS matter was disposed of and the investigation had culminated in the filing of a charge-sheet.

The court placed significant weight on the fact that the applicant’s case was identical to that of co-accused Tarun Baghel, who had already been granted bail by the same court.

Given that the trial was expected to take time and the investigation was complete, the court determined that continued incarceration was unnecessary.

The court ordered his release upon furnishing a personal bond with two sureties, subject to specific conditions: the applicant must not seek unnecessary adjournments, must appear personally at key trial stages (charge framing and Section 351 BNSS statements), and must comply with trial court schedules.

Failure to comply would allow the trial court to treat the default as an abuse of liberty and initiate proceedings under Sections 209 or 269 of the BNS.