Chhattisgarh High Court

Bail is maintainable for NDPS offences involving contraband below commercial quantity post-filing of charge-sheet.

SAHODRA DAHARIYA vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: March 17, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

On 07.01.2026, acting on a tip-off, the police intercepted a motorcycle and seized 7.250 kg of Ganja from the possession of the applicants

Source reference: para. 3

An offense was registered under Section 20(B) of the Narcotic Drugs and Psychotropic Substances (NDPS) Act, 1985

Source reference: para. 3

The applicants were arrested on 07.01.2026 and 09.02.2026

Source reference: para. 4

The applicants moved the High Court for regular bail, contending false implication and noting that the investigation was complete with the charge-sheet already filed

Source reference: para. 4

The State opposed bail, noting that while the quantity was below commercial limits, one applicant (Ramkumar Khande) had a previous criminal antecedent under Istagasa

Source reference: para. 5
02

Issues

1. Whether the applicants are entitled to the grant of regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, given that the seized contraband is below the commercial quantity

Source reference: para. 7
03

Law Applied

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

Source reference: para. 2

It also considered Section 20(B) of the NDPS Act, 1985, which penalizes the production, manufacture, possession, sale, purchase, transportation, or use of cannabis

Source reference: para. 2

The court referenced procedural requirements for trial attendance and the consequences of misusing liberty under Sections 209, 269, 351, and 84 of the BNSS

Source reference: para. 8
04

Reasoning

The Court analyzed the gravity of the offense in light of the quantity of the seized substance.

Source reference: para. 7

It noted that the 7.250 kg of Ganja recovered is less than the "commercial quantity," which reduces the statutory rigors for bail

Source reference: para. 7

The Court balanced the State's concern regarding the criminal antecedent of applicant Ramkumar Khande against the fact that the remaining applicants had no prior records

Source reference: para. 5, 7

Furthermore, the Court observed that since the charge-sheet had been filed and the applicants had been in custody for over a month, their continued detention was not warranted provided they adhered to strict conditions to ensure their presence during the trial

Source reference: para. 7-8
05

Holding

The Court allowed the bail applications and ordered the release of the applicants on furnishing a personal bond with two sureties each

The holding clarified that bail is appropriate when the seized quantity is non-commercial and the investigation is complete

Source reference: para. 7

The relief was granted subject to specific conditions: the applicants must not seek adjournments when witnesses are present, must appear on all fixed dates, and must comply with trial procedures under the BNSS, failing which the trial court may treat it as an abuse of liberty

Source reference: para. 8
Chhattisgarh High Court

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SAHODRA DAHARIYAvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · March 17, 2026

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