Chhattisgarh High Court
Criminal LawCriminal Procedure and Evidence

Completed investigation, substantial custody, and parity with bailed co-accused justify regular bail.

SANATAN MANDAL vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: October 12, 20262 MIN READSOURCE JUDGMENT
Completed investigation, substantial custody, and parity with bailed co-accused justify regular bail.. SANATAN MANDAL vs STATE OF CHHATTISGARH. Chhattisgarh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The complainant alleged that, between 7 November and 6 December 2025, he was induced through WhatsApp and a mobile application to transfer ₹1,49,50,000 to various bank accounts for purported online share trading; further payment demands led him to suspect fraud.

Source reference: para. 2

The applicant was arrested in connection with the resulting crime registered under Sections 318(4), 317(4) and 3(5) of the Bharatiya Nyaya Sanhita, 2023 (BNS), and Section 66D of the Information Technology Act, 2000.

Source reference: para. 2

He sought regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS).

Source reference: para. 1

He submitted that the investigation was complete, the charge-sheet had been filed, he had been in custody since 21 February 2026, had no criminal antecedents, and that co-accused had been granted bail.

Source reference: para. 3

The State opposed bail on the basis of the seriousness of the allegations.

Source reference: para. 4
02

Issues

1. Whether the applicant should be released on regular bail under Section 483 of the BNSS, having regard to the circumstances of the case.

Source reference: paras. 1, 6

2. Whether the bail granted to co-accused, along with the applicant’s custody, antecedents and the status of the investigation and trial, supported his release.

Source reference: paras. 3, 6
03

Law Applied

Section 483 of the BNSS provides the procedural basis for the High Court to consider an application for regular bail.

Source reference: para. 1

The Court assessed bail by considering the nature and gravity of the allegations, completion of the investigation and filing of the charge-sheet, the applicant’s criminal antecedents and period in custody, the likely time for trial, and the fact that co-accused had been granted bail.

Source reference: para. 6

The judgment cites no precedent and does not separately analyse the elements of the charged offences.

Source reference: no citation
04

Reasoning

The Court weighed the seriousness of the allegations against the completed investigation and filing of the charge-sheet, the applicant’s lack of criminal antecedents, his custody since 21 February 2026, and the likelihood that trial would take time.

Source reference: para. 6

It also considered the bail orders granted to co-accused.

Source reference: para. 6

On those combined circumstances, and without expressing any opinion on the merits, the Court found the applicant entitled to bail.

Source reference: para. 6
05

Holding

The Court allowed the bail application.

It directed that the applicant be released upon executing a personal bond of ₹50,000 with one surety for the like sum to the satisfaction of the trial Court.

Source reference: paras. 6–7

Bail was subject to conditions against influencing persons acquainted with the case, conduct prejudicial to a fair and expeditious trial, and appearance on every date fixed by the trial Court.

Source reference: paras. 6–7

The Court clarified that its observations were limited to the bail application and that the trial Court must decide the case on its merits.

Source reference: para. 8
06

Acts & Sections Cited

4 provisions across 2 statutes referred to in this judgment. Each provision opens on LawLens.

Bharatiya Nagarik Suraksha Sanhita, 20231

Bharatiya Nyaya Sanhita, 20233

Chhattisgarh High Court

Original Court PDF

SANATAN MANDALvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · October 12, 2026

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