Jammu and Kashmir High Court

Bail Granted to Renal Transplant Recipient After Filing of Charge-Sheet in Economic Offence Case

IRFAN MAJID ZARGAR vs UNION TERRITORY THROUGH ECONOMIC OFFENCES WING (CRIME BRANCH) AND OTHERS

Jammu and Kashmir High CourtJUDGMENT: May 13, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner, a 42-year-old former Branch Head of HDFC Bank, Shopian, was arrested on February 13, 2026, in Case FIR No. 30/2025

Source reference: p. 1-2

He is accused of orchestrating a financial scam involving approx. ₹5.86 crore, including forging cheques of M/S Freshmen Foods Pvt. Ltd., issuing fake Fixed Deposit receipts, and making fictitious entries to mask a physical cash shortfall

Source reference: p. 2-3, 5-6

The petitioner sought bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), citing his status as a kidney transplant recipient (2015) requiring a sterile environment and medication, the completion of the investigation, and the fact that co-accused persons had already been granted bail

Source reference: p. 3-5

The respondent opposed bail, labeling the petitioner the "principal architect" of the fraud

Source reference: p. 5
02

Issues

1. Whether the petitioner is entitled to bail under Section 483 of the BNSS considering the completion of the investigation and the principle of parity with co-accused

Source reference: p. 2, 8

2. Whether the petitioner’s medical condition as a renal transplant patient warrants the grant of bail under the mandate of Article 21 of the Constitution of India

Source reference: p. 4, 9-10
03

Law Applied

The Court primarily applied Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 regarding bail

Source reference: p. 1

the principle that "bail is the rule and jail is the exception" as established in Dataram Singh v. State of Uttar Pradesh

Source reference: p. 8

doctrine from Satender Kumar Antil v. CBI, which mandates that unnecessary incarceration should be avoided after the filing of a charge-sheet

Source reference: p. 7

Sanjay Chandra v. CBI, which held that bail in economic offences should not be withheld as a form of pre-trial punishment

Source reference: p. 8-9

Right to Life under Article 21 of the Constitution concerning the petitioner's medical necessity

Source reference: p. 4, 10
04

Reasoning

The Court reasoned that since the investigation is complete and the charge-sheet has been filed, custodial interrogation is no longer necessary

Source reference: p. 7

It dismissed the prosecution's apprehension regarding evidence tampering, noting that all documentary and electronic evidence is already in judicial custody

Source reference: p. 7-8

The Court observed that six co-accused had been granted bail by the trial court, and the petitioner was entitled to similar treatment under the principle of parity

Source reference: p. 8

The Court evaluated the petitioner's medical records from Sir Ganga Ram Hospital, confirming his status as a kidney transplant patient. It determined that the prison environment could not provide the required hygiene, renal diet, and medical supervision necessary to prevent organ failure or infection, thereby necessitating bail on humanitarian and constitutional grounds

Source reference: p. 10
05

Holding

The Court answered the issues in the affirmative, holding that the petitioner’s medical condition and the completion of the investigation outweighed the severity of the economic allegations

The bail application was allowed, and the petitioner was ordered to be released on a personal bond of ₹1,00,000 with two sureties, subject to conditions including non-interference with witnesses, surrendering his passport, and not leaving the UT of J&K without permission

Source reference: p. 10-11
Jammu and Kashmir High Court

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IRFAN MAJID ZARGARvsUNION TERRITORY THROUGH ECONOMIC OFFENCES WING (CRIME BRANCH) AND OTHERS

Jammu and Kashmir High Court · May 13, 2026

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