Expeditious Trial Conclusion Directed Where Prosecution Evidence Against Applicant Is Complete Despite Newly Arraigned Co-Accused.

The applicant, Sanjeev Jangde, was arrested on 21.03.2025 in connection with Crime No. 77/2025 involving alleged cyber fraud amounting to Rs. 1.30 crore.

The prosecution alleged that the applicant facilitated co-accused persons by procuring bank accounts from villagers to route fraudulent proceeds.

This is the applicant's third bail application; two previous applications were rejected on 15.07.2025 and 23.11.2025.

The applicant moved this subsequent application on the grounds that the trial qua him was concluded, all prosecution witnesses had been examined, and a supplementary charge-sheet had been filed against four new accused, which would significantly delay the final outcome.

1. Whether the filing of a supplementary charge-sheet against newly added accused and the conclusion of evidence against the current applicant constitute a "change in circumstances" sufficient for the grant of bail.

2. Whether the applicant's continued incarceration, following the examination of all original prosecution witnesses, is necessitated given the nature of the evidence.

Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS) regarding the grant of regular bail.

Principles of "change in circumstances" in successive bail applications and the right to an expeditious trial to prevent pre-trial punishment.

Section 193(3) and 193(9) of the BNSS concerning supplementary investigations and the filing of final reports.

The court evaluated the applicant's prolonged incarceration since March 2025 against the current status of the trial.

While the State opposed bail citing the gravity of the fraud (Rs. 1.30 crore) and the applicant's role in providing bank details to the "upper layer", the court observed that all prosecution witnesses cited in the original charge-sheet had already been examined.

The court noted that although a supplementary charge-sheet was filed against four new persons—likely delaying the holistic conclusion of the case— the trial specifically regarding the present applicant was "at the verge of its completion".

Rather than granting bail, the court determined that the interests of justice would be better served by directing a time-bound conclusion of the trial to resolve the applicant's legal status.

The Court issued a directive to the Trial Court to proceed expeditiously and conclude the trial by passing a judgment within two months from the date of receipt of the order, provided there is no legal impediment.

The office was directed to communicate this order to the trial court immediately for compliance.