Bail Warranted Where Post-Mortem Recorded Snakebite and No Independent Criminal Antecedents Existed.

The applicant sought regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, in four cases arising from allegations that he and others forged documents and medical records to obtain ₹4,00,000 under the Government Snake Bite/Poisonous Animal Bite Death Assistance Scheme, causing loss to the State exchequer.

The cases involved offences under Sections 420, 467, 468, 471 and 34 of the Indian Penal Code, and Sections 318(4), 336(3), 338, 340(2), 3(5), 341(2), 341(4) and 61(2) of the Bharatiya Nyaya Sanhita, 2023.

The applicant maintained that he had no role in procuring the assistance and relied on the post-mortem report recording snake bite as the cause of death; the State opposed bail on the ground that the applicant had concealed the actual cause of death and fraudulently secured the payment.

The applicant had been in custody since 19 June 2026.

1. Whether the applicant had made out a case for regular bail in the four connected cases, having regard to the allegations, investigation material, and circumstances of detention.

2. Whether the applicant’s continued pre-trial detention was warranted where the post-mortem report recorded snake bite as the cause of death and the allegations remained to be tested at trial.

Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, empowers the High Court to grant regular bail.

In deciding the applications, the Court considered the nature and gravity of the allegations, the material collected during investigation, the applicant’s period of detention, antecedents, and the likely duration of trial.

The Court weighed the allegations of fraudulent procurement against the post-mortem report, which recorded snake bite as the cause of death, and considered the applicant’s detention since 19 June 2026.

It treated the allegations as matters for determination at trial and found that continued pre-trial detention would serve no fruitful purpose, particularly because the trials were likely to take time.

The Court therefore concluded that the applicant had made out a case for bail, without expressing any view on the merits.

It directed the applicant’s release on a personal bond of ₹50,000 to the satisfaction of the concerned trial Court, subject to conditions requiring him to remain available for police interrogation, refrain from influencing persons acquainted with the case, and avoid conduct prejudicial to a fair and expeditious trial.

The trial Court must decide the cases on their own merits.