Chhattisgarh High Court

Bail granted to first-time offenders under Excise Act where investigation is complete and trial is pending.

CHANDRAMA RATRE vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: May 07, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Applicants, Chandrama Ratre and Fagni Bai Ratre, were arrested on 05.04.2026 in connection with Crime No. 41/2025 at Police Station Khallari, District Mahasamund

Source reference: para. 2, 3

Following a secret tip, the police seized 19 liters of Mahua liquor from their possession

Source reference: para. 2

The Applicants were charged under Section 34(2) of the C.G. Excise Act

Source reference: para. 1

The Applicants moved the High Court for regular bail, contending they were falsely implicated, had no prior criminal record, and that the charge-sheet had already been filed

Source reference: para. 3
02

Issues

Whether the Applicants are entitled to the grant of regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, considering the quantity of liquor seized and the duration of their incarceration

Source reference: para. 1, 6
03

Law Applied

Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, regarding the power of the High Court to grant bail

Source reference: para. 1

Section 34(2) of the C.G. Excise Act, which prescribes a minimum punishment of one year and a maximum of three years for the unlawful possession of liquor

Source reference: para. 3

Procedural compliance was mandated under Section 269 of the Bharatiya Nyaya Sanhita (BNS) for non-appearance, Section 84 of the BNSS for proclamations, Section 209 of the BNS for failure to appear after proclamation, and Section 351 of the BNSS for recording statements

Source reference: para. 7
04

Reasoning

The court evaluated the gravity of the allegations involving the seizure of 19 liters of Mahua liquor against the mitigating factors presented by the defense

Source reference: para. 6

It noted that the Applicants had no criminal antecedents and had already been in custody since 05.04.2026

Source reference: para. 3, 4

The court emphasized that the investigation was effectively complete as the charge-sheet had been filed

Source reference: para. 6

Given that the maximum sentence for the offense is three years and the trial was expected to take considerable time, the court determined that further pre-trial detention was not warranted

Source reference: para. 3, 6
05

Holding

The court allowed the bail application and ordered the release of the Applicants on furnishing a personal bond with two sureties

The holding is contingent upon several conditions: the Applicants must not seek unnecessary adjournments, must be present for all trial dates (specifically for framing charges and recording statements under Section 351 BNSS), and any misuse of liberty or failure to appear under Section 84 BNSS will result in proceedings under Section 209 BNS

Source reference: para. 7
Chhattisgarh High Court

Original Court PDF

CHANDRAMA RATREvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · May 07, 2026

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