Bail granted where medical evidence shows minor injury despite allegations of attempt to murder.

The applicant, Lakhan Singh, was arrested on 06.03.2026 following an incident during the Holi festival on 05.03.2026

Following a dispute over the quantity of liquor being distributed, the applicant allegedly assaulted the victim, Rajkumar Panika, on the head with a "brass lota"

Crime No. 21/2026 was registered at Police Station Kotadol for an offense under Section 109 of the Bharatiya Nyaya Sanhita (BNS)

Upon completion of the investigation, a charge-sheet was filed

The applicant moved the High Court for regular bail, asserting false implication and highlighting that the Medico-Legal Case (MLC) report showed only swelling despite the injuries being characterized as "grievous"

Whether the applicant is entitled to the grant of regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS) considering the nature of the injury and the procedural status of the case

The court primarily applied Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, which governs the grant of regular bail

The substantive offense charged was Section 109 of the Bharatiya Nyaya Sanhita (BNS), 2023 (corresponding to Section 307 of the Indian Penal Code regarding attempt to murder)

The court also invoked procedural safeguards under Sections 84, 209, 269, and 351 of the BNSS to mandate the applicant's presence during trial and prevent the abuse of the liberty of bail

The Court evaluated the nature and gravity of the allegations against the evidence presented in the charge-sheet.

It noted the discrepancy between the prosecution’s claim of "grievous" injury and the MLC report, which recorded only swelling

The Court further observed that the investigation was complete and the charge-sheet had already been filed before the competent court

In deciding to grant bail, the Court placed significant weight on the applicant's lack of previous criminal antecedents and the fact that he had been in custody since 06.03.2026

Given that the conclusion of the trial was expected to take considerable time, the Court determined that continued pretrial detention was unnecessary, provided that strict conditions were imposed to ensure the applicant's cooperation with the judicial process

The holding clarified that the applicant is entitled to bail due to the nature of the medical findings (swelling only), the filing of the charge-sheet, and his clean criminal record

The relief is contingent upon several conditions, including a prohibition on seeking adjournments during evidence, mandatory personal appearance at specific trial stages, and potential proceedings under Sections 209 and 269 of the BNS/BNSS in the event of default or non-appearance