Completion of investigation alone does not justify bail in a grave murder case supported by eyewitnesses.

The petitioner, accused No. 2, sought bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), in a Sessions case arising from Crime No. 161/2025.

The prosecution alleged that he and accused No. 1 conspired to kill the deceased and that the petitioner strangled the deceased with the deceased’s shirt at the petitioner’s rented house on 16 November 2025.

The charge sheet had been filed for offences under Sections 61(2) and 103(1), read with Section 3(5), of the Bharatiya Nyaya Sanhita, 2023 (BNS).

The petitioner asserted his innocence and contended that the deceased had been intoxicated and the incident occurred during a quarrel in the heat of passion.

Whether the petitioner had established grounds for release on bail under Section 483 BNSS, given the allegations, supporting material, and gravity of the charged offences.

Whether completion of the investigation and filing of the charge sheet, together with the petitioner’s local residence and willingness to comply with conditions, justified bail at that stage.

The Court considered Section 483 BNSS, which empowers the High Court to grant bail, and the charged offences under Sections 61(2), 103(1), and 3(5) BNS.

It reiterated that bail is the rule and jail the exception, while treating the gravity and nature of the alleged offence, the available prosecution material, and the risk of interference with witnesses as relevant considerations in deciding bail.

The Court cited no precedent.

The Court found that the complaint and prosecution papers disclosed a specific alleged role for the petitioner, that eyewitness statements were consistent with the complaint, and that the post-mortem report attributed death to mechanical asphyxia caused by strangulation.

It considered the offence grave and punishable with death or imprisonment for life.

It rejected the petitioner’s account of intoxication and a heat-of-passion quarrel as insufficient, at the bail stage, to displace the prosecution case.

The filing of the charge sheet did not itself warrant bail; the Court also considered the alleged relationship between the petitioner and accused No. 1 as creating a risk of influencing witnesses or otherwise hampering the prosecution.

It left the petitioner at liberty to apply to the trial Court for bail after the complainant and eyewitnesses had been examined.