Bail granted to journalist as Sting Operation evidence was submitted to authorities before extortion FIR was registered.

The applicant, a journalist with Tehelka Digital News, conducted sting operations to expose illegal prenatal sex determination and abortions in Dewas, Madhya Pradesh

Following these investigations, she shared the video evidence with senior authorities, including the Health Department and the DGP, on April 6th and 7th, 2026

Subsequently, the complainant filed an FIR (Crime No. 204/2026) alleging that the applicant conspired to extort money through blackmail

The applicant was formally arrested on April 13, 2026, and after her bail was rejected by the Trial Court on May 13, 2026, she moved the High Court for regular bail

1. Whether the applicant is entitled to regular bail under Section 483 of the Bhartiya Nagarik Suraksha Sanhita, 2023 (formerly Section 439 CrPC) in view of the sequence of events and the nature of the allegations.

Section 483 of the Bhartiya Nagarik Suraksha Sanhita, 2023 (corresponding to Section 439 of the CrPC, 1973) governing the discretionary power of the High Court to grant bail

Section 480(3) of the BNSS (Section 437(3) CrPC) regarding conditions for bail

principles of parity in bail (as a co-accused was already released) and the absence of prima facie intent for extortion where evidence had already been submitted to state authorities

The Court observed that the applicant had already dispatched the sting operation videos to the Commissioner of the Health Department, the NHRC, and the DGP between April 6th and April 7th, 2026

The Court reasoned that if the material was already provided to the highest state officials before the FIR was registered on April 7th, the possibility of the applicant using that same material to extort or blackmail the complainant was significantly diminished

the Court noted that the applicant had already been granted bail in three related crimes (Nos. 194, 195, and 205 of 2026) and that a co-accused had been released on bail, establishing a basis for parity

The High Court allowed the application and directed the release of the applicant on bail upon furnishing a personal bond of Rs. 1,00,000/- with one solvent surety, subject to conditions of regular appearance and non-violation of the law during the trial period