Filing of charge-sheet and period of detention justify bail notwithstanding existence of multiple criminal antecedents.

On September 30, 2025, the complainant, Raju Chauhan, was allegedly assaulted by the three applicants with a metal rod and fists while loading paddy into a truck

The applicants reportedly abused the complainant, robbed ₹2,000 from his pocket, and issued threats

Applicant Nos. 1 and 2 were arrested on October 2, 2025, and Applicant No. 3 was arrested on October 3, 2025

Following the investigation, a charge-sheet was filed, and the case reached the stage of framing charges

The applicants moved the High Court for regular bail, citing a lack of direct evidence, inconclusive medical/FSL reports, and prolonged detention

1. Whether the applicants are entitled to the grant of regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, in view of the filed charge-sheet and the nature of the evidence collected

The court primarily applied Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, which provides the High Court with the power to grant bail

The substantive offences were registered under the Bharatiya Nyaya Sanhita (BNS), including Sections 296 (obscene acts), 115(2) (voluntarily causing hurt), 351(2) (criminal intimidation), 309(4) (robbery), 324(4) (mischief), 109 (abetment), 238 (disappearance of evidence), and 3(5) (joint liability)

The court also considered the relevance of criminal antecedents and the evidentiary value of FSL reports in bail adjudications

The Court evaluated the gravity of the offence against the specific evidence presented by the prosecution.

It noted that although the State opposed bail due to the applicants' criminal histories (Applicant 1: 5 cases; Applicant 2: 6 cases; Applicant 3: 5 cases), most of these past cases were no longer pending

The Court observed that the medical evidence only reflected a hairline fracture, and the FSL report failed to confirm that the blood on the seized iron rod was of human origin

Additionally, the actual recovery from the applicants was minimal—₹300 each from Applicant Nos. 1 and 3

Considering that the investigation was complete, the charge-sheet had been filed, and the trial was likely to be prolonged, the Court determined that continued detention was not warranted

The holding emphasized that the filing of the charge-sheet and the period of detention (since October 2025) justified the grant of bail

The relief was made subject to the applicants furnishing a personal bond with two sureties each and adhering to strict conditions, including a prohibition on seeking adjournments during evidence and a mandatory presence at key trial stages like the framing of charges and recording of statements under Section 351 of the BNSS