Filing of charge-sheet justifies bail in theft cases notwithstanding a single similar criminal antecedent.

On January 12, 2026, the complainant discovered that the rear window of his car, parked near Apollo Diagnostic Clinic in Raipur, had been broken

Stolen items included a laptop bag containing ₹10,00,000 cash, an HP laptop, a Samsung tablet, a hard disk, and a sling bag with credit/debit cards

CCTV footage revealed 4–5 individuals involved in the incident

The applicant was arrested on January 12, 2026, following the registration of Crime No. 09/2026 at Police Station Ganj

The applicant sought regular bail on the grounds that the charge-sheet had been filed, he had been in custody for several months, and he possessed only one criminal antecedent

1. Whether the applicant is entitled to the grant of regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, in light of the filing of the charge-sheet and his period of detention

Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), regarding the High Court's power to grant bail

Sections 305(c) (theft in a dwelling house/transport), 112(2) (petty organized crime), 324(5) (mischief), and 3(5) (common intention) of the Bharatiya Nyaya Sanhita (BNS)

The court also considered the judicial principle that the completion of an investigation (filing of a charge-sheet) and the duration of pretrial detention are significant factors in exercising discretionary power for bail, even in the presence of a criminal antecedent

The Court analyzed the gravity of the allegations, involving a coordinated theft of significant cash and electronics, alongside the procedural status of the case

It noted that the applicant had been in custody since January 12, 2026, and that the investigation reached a stage where the charge-sheet was already filed

Although the State Counsel opposed bail by highlighting the applicant's single criminal antecedent of a similar nature from the same year, the Court determined that this alone was insufficient to justify further detention

The Court reasoned that since the trial is likely to be protracted, and the investigation is complete, the applicant met the criteria for release

The holding clarified that a single criminal antecedent of identical nature does not automatically disqualify an applicant from bail if the investigation is complete and the trial is expected to take time

The applicant was ordered to be released on a personal bond with two sureties, subject to specific conditions: an undertaking not to seek unnecessary adjournments [para. 8(i)], mandatory attendance at all trial dates under threat of Section 269 BNS proceedings [para. 8(ii)], and strict compliance with appearance requirements during key trial stages [para. 8(iv)]