Bail granted where implication rests solely on co-accused’s memorandum statement and no incriminating articles are recovered.

On January 13, 2026, an explosion occurred involving a gas tank on a pickup vehicle (Registration No. CG 04 PZ 9485) on the National Highway

The prosecution alleged that the incident resulted from the negligent handling of inflammable materials by the driver and his associates, causing loss of life, property damage to nearby houses, and significant infrastructure damage

While the FIR initially named the driver, conductor, and owner, the present applicant was subsequently implicated solely based on a memorandum statement provided by the co-accused driver

No incriminating articles or gas cylinders were seized from the applicant; the cylinders were recovered from another co-accused, Pokhraj Joshi

The applicant, who has one prior criminal antecedent, was arrested on January 15, 2026, and a charge-sheet has since been filed

Whether the applicant is entitled to the grant of regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, considering he was implicated based on a co-accused's memorandum statement and the investigation is complete

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

Sections 110 (Punishment of abetment), 125(a) (Act endangering life or personal safety), 287 (Negligent conduct with respect to fire), and 3(5) (Joint liability) of the Bharatiya Nyaya Sanhita (BNS), 2023

procedural conditions for bail under Sections 269, 84, 209, and 351 of the BNSS

the Court observed that the applicant’s involvement was predicated entirely on the memorandum statement of a co-accused, rather than direct evidence or recovery of incriminating material from his possession

While the State opposed bail citing the gravity of the explosion and the applicant's single criminal antecedent, the Court weighed these factors against the fact that the charge-sheet had already been filed and the applicant had been in judicial custody since mid-January 2026

The Court determined that since the investigation was concluded and the trial was expected to take a considerable amount of time, continued incarceration was not warranted

The holding clarified that the nature of the evidence (memorandum statement) and the duration of custody justified bail despite the seriousness of the incident

The grant of bail was made subject to several conditions, including a prohibition on seeking adjournments during witness testimony, mandatory attendance at trial proceedings, and strict compliance with proclamations to avoid proceedings under Section 209 of the BNS