Bail granted on parity, completed investigation, prolonged detention, and a non-pending criminal antecedent.

The applicant was arrested in connection with Crime No. 843/2026 registered at Police Station Civil Line, Bilaspur, for offences under Sections 420, 467, 468, 471 and 120-B of the IPC.

The prosecution alleged that the applicant, in connivance with other accused persons, concealed the actual cause of death and fraudulently obtained ₹4,00,000 under the Government Snakebite/Poisonous Animal Bite Death Assistance Scheme, causing wrongful loss to the State and corresponding wrongful gain to the accused.

The applicant had been in custody since 19 June 2026, and the charge-sheet had been filed.

He relied on bail orders granted in similar cases arising from alleged misuse of the same scheme.

He also had one criminal antecedent from 2024, in which anticipatory bail had been granted and the charge-sheet had been filed.

The State opposed bail on the grounds of the applicant’s alleged participation in the fraud and his criminal antecedent.

Whether the applicant was entitled to regular bail under Section 483 of the BNSS in view of the allegations of cheating, forgery, use of forged documents and criminal conspiracy.

Whether the applicant’s period of custody, filing of the charge-sheet, grant of bail to co-accused or similarly situated accused, and criminal antecedent justified release on bail.

The Court applied Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, governing the High Court’s power to grant regular bail.

The alleged offences were under Sections 420, 467, 468, 471 and 120-B of the Indian Penal Code, relating respectively to cheating, forgery of valuable security or documents, forgery for the purpose of cheating, using forged documents as genuine, and criminal conspiracy.

In determining bail, the Court considered the nature and gravity of the allegations, the period of detention, the filing of the charge-sheet, the applicant’s criminal antecedent, and parity with accused persons granted bail in similar cases.

No separate judicial precedent was cited.

The Court acknowledged the prosecution’s allegation that the applicant had acted in connivance with co-accused persons to suppress the actual cause of death and wrongfully obtain ₹4,00,000 from the government scheme.

Nevertheless, the applicant had remained in custody since 19 June 2026, the charge-sheet had been filed, and similar accused persons involved in alleged misuse of the same scheme had already been granted bail by the High Court in MCRC Nos. 6205/2026, 6251/2026, 6956/2026 and 6871/2026.

The Court further noted that the applicant’s sole criminal antecedent related to 2024, for which anticipatory bail had been granted and the charge-sheet had already been filed.

Balancing the seriousness of the allegations against these mitigating circumstances, the Court held that continued detention was not warranted.

The applicant, Kamta Prasad Sahu, was directed to be released on regular bail upon furnishing a personal bond and two sureties in the like amount to the satisfaction of the concerned trial court.

The release was subject to conditions requiring him not to seek adjournments when witnesses were present, to remain present before the trial court on scheduled dates, to appear personally at the opening of the case, framing of charge and recording of his statement under Section 351 of the BNSS, and to comply with the consequences of non-appearance or misuse of bail liberty.