Completion of investigation justifies regular bail in fatal motor accidents involving rash driving and intoxication.

The applicant was arrested in connection with an incident where he allegedly drove an Eco Van while intoxicated, in a rash and negligent manner

The prosecution alleged that the applicant struck and killed a pedestrian, Kanshi Ram Sahu, and subsequently hit two other individuals, causing injuries, before failing to stop the vehicle

The applicant contended that although the MLC mentioned alcohol consumption, no blood sample was taken to verify the exact quantity, and his failure to stop was due to fear of being assaulted by a mob

The applicant has been in custody since 07.10.2025, and the charge-sheet has already been filed

This is the first bail application filed under Section 483 of the Bhartiya Nagarik Suraksha Sanhita (BNSS), 2023

Whether the applicant is entitled to the grant of regular bail under Section 483 of the BNSS, 2023, in light of the nature of the allegations and the period of detention

Section 483 of the Bhartiya Nagarik Suraksha Sanhita (BNSS), 2023, regarding the discretionary power of the High Court to grant bail

substantive offences charged under the Bharatiya Nyaya Sanhita (BNS), specifically Sections 281 (rash driving), 125(A) (causing hurt by act endangering life), 105 (culpable homicide not amounting to murder), and 125(B)

Sections 39/192(1), 184, and 185 of the Motor Vehicle Act concerning driving under the influence and licensing violations

The Court balanced the gravity of the allegations—specifically the death of one individual and injuries to others—against the procedural progress of the case and the rights of the accused

The Court observed that the accident was primarily attributed to rash and negligent driving

Crucially, the Court noted that the investigation was largely complete as the charge-sheet had been filed before the competent court

Considering that the applicant had no criminal antecedents and had already undergone significant detention since October 2025, the Court reasoned that since the trial was unlikely to conclude soon, further incarceration was unnecessary

the applicant is entitled to bail provided he complies with several conditions, including: (i) not seeking adjournments during evidence; (ii) personal appearance on all trial dates; and (iii) strict adherence to Sections 269, 209, and 351 of the BNS/BNSS regarding appearance and abuse of liberty

The trial court was directed to treat any default as a ground to revoke the liberty of bail