Expeditious Conclusion of Trial Mandated While Disposing Second Bail Application Where Trial Reaches Final Stages.

The applicant filed a second bail application under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS).

The prosecution alleged that the applicant assisted co-accused persons in procuring bank accounts from villagers to facilitate a cyber fraud involving approximately ₹1.30 crore.

This followed a communication from the Indian Cyber Crime Coordination Centre (I4C) regarding fraudulent deposits in Mungeli District.

The applicant was arrested on 21.03.2025.

While the 13 prosecution witnesses in the original charge-sheet have been examined, a supplementary charge-sheet was later filed against four newly arrested accused persons.

The applicant’s first bail application (MCRC No. 2908/2025) was rejected on merits on 20.06.2025.

1. Whether the applicant is entitled to regular bail in a second application given the stage of the trial and his duration of incarceration.

2. Whether the filing of a supplementary charge-sheet against co-accused necessitates a fresh examination of witnesses, thereby justifying bail due to potential trial delay.

Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, which governs the power of the High Court to grant bail.

Sections 111 (organized crime), 317(2), 317(4), 317(5) (stolen property/cheating), and 3(5) (common intention) of the Bharatiya Nyaya Sanhita (BNS), 2023.

Section 193(9) of the BNSS regarding further investigation and supplementary charge-sheets on the timeline of the trial.

The Court evaluated the applicant’s plea for bail based on the prolonged custody since March 2025 and the assertion that a supplementary charge-sheet would restart witness examinations, causing delay.

The Court observed that despite the supplementary filing against other accused, the trial against the present applicant is "at the verge of its completion" with original witnesses already examined.

The Court weighed the State's objection regarding the severity of the online fraud—specifically that the applicant provided sensitive banking credentials (ATM, Aadhaar, Mobile No.) to facilitate a ₹1.30 crore scam.

Rather than granting liberty, the Court determined that the proximity to a final judgment outweighed the grounds for bail.

The Trial Court was directed to expedite the proceedings and endeavor to conclude the trial and pass a judgment within two months from the receipt of the order.