Completion of investigation and filing of the charge sheet supported grant of anticipatory bail.

The petitioners, Accused Nos. 3 and 5 in Crime No. 61/2026, sought anticipatory bail in a case registered by Cubbon Park Police for offences under Sections 108, 115(2), 351(2) read with Section 3(5) of the Bharatiya Nyaya Sanhita, 2023 (BNS)

The complaint alleged that Accused No. 5 had quarrelled with the deceased, Suresh Kumar Purohit, in Rajasthan and later instigated others to assault him in Bengaluru on the night of 2–3 April 2026; the deceased died by suicide later that day

The FIR was registered on 22 April 2026, nearly three weeks after the death

The Sessions Court rejected the petitioners’ bail application on 2 September 2026

The investigation was complete and the charge sheet had been filed by the time this petition was considered

Whether the petitioners were entitled to anticipatory bail in Crime No. 61/2026

Whether anticipatory bail should be granted subject to conditions in light of the allegations, the circumstances of the deceased’s death, and the completed investigation

The petition was considered under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), the provision invoked for anticipatory bail

The alleged offences were under Sections 108, 115(2), 351(2) read with Section 3(5) of the BNS

The Court also referred to its earlier order in Crl.P. No. 6899/2026, which had observed that the absence of injuries suggesting a brutal assault, and an alleged assault with hands and legs following a quarrel, did not by themselves provide a sufficient reason for a prudent person to commit suicide

The order does not set out a separate general test for anticipatory bail.

The Court considered the alleged prior quarrel and threat, the subsequent alleged assault, and the fact that the deceased died by suicide on the same date

It noted the delay of nearly three weeks in registering the FIR

It relied on its earlier assessment of the medical and surrounding circumstances, including the absence of injuries indicating a brutal assault

As the investigation was complete and the charge sheet had been filed, the Court concluded that anticipatory bail could be granted, subject to conditions

Each petitioner must appear before the Investigating Officer within 15 days, execute a personal bond of ₹1,00,000 with two sureties (one local), attend the Trial Court unless exempted, cooperate with the police, refrain from tampering with witnesses, and not commit similar offences in future