Financial links to co-accused possessing commercial quantity contraband justify denial of regular bail.

The applicant filed a first bail application following his arrest in connection with Crime No. 600/2025

On August 3, 2025, police conducted a search based on secret information, seizing 10.23 grams and 402.64 grams of heroin from co-accused Suvit Shrivastava and Lavjeet Singh, respectively

The applicant was subsequently implicated via memorandum statements of the co-accused.

Investigation revealed that the applicant allegedly facilitated illegal transactions for the sale of "chitta" (contraband), including a transfer of Rs. 1,10,700/- from his Axis Bank account to the account of co-accused Ashvin Chandravanshi

The applicant has been in custody since August 16, 2025

1. Whether the applicant is entitled to the grant of regular bail under Section 483 of the Bhartiya Nagarik Suraksha Sanhita, 2023, given that no contraband was directly seized from his possession

2. Whether the financial transactions and memorandum statements of co-accused provide sufficient prima facie evidence of the applicant's involvement in a commercial-quantity narcotics offense to warrant the denial of bail

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

Substantive charges were considered under Sections 21(C), 27, 27(A), and 29 of the Narcotic Drugs and Psychotropic Substances (NDPS) Act, 1985, which govern commercial quantity possession, financing, and abetment/criminal conspiracy

Additionally, the court noted the application of Section 111 of the Bhartiya Nyaya Sanhtia (BNS), 2023, concerning organized crime, and Section 25 of the Arms Act

The court adhered to the principle that in cases involving commercial quantities of narcotics, the gravity of the offense and prima facie evidence of involvement in the trade outweigh the absence of physical recovery from a specific individual

The Court analyzed the applicant's role not through physical possession, but through his alleged involvement in the financial nexus of the drug trade.

Although the applicant argued that no contraband was seized from him and he had no criminal antecedents, the Court found the prosecution's evidence regarding the money trail compelling.

Specifically, the transfer of Rs. 1,10,700/- to a co-accused for "chitta" transactions was viewed as prima facie evidence of participation in the offense

The Court further observed that the total heroin seized from the co-accused (412.87 grams) constituted a commercial quantity, thereby invoking more stringent scrutiny

Consequently, the Court determined that the nature and gravity of the offense, coupled with the evidence of illegal financial transactions, precluded the grant of bail, notwithstanding the duration of the applicant's pre-trial detention

The High Court of Chhattisgarh rejected the bail application.

The Court directed the trial court to proceed with and conclude the trial expeditiously