Chhattisgarh High Court

First Bail Application granted on grounds of parity and completion of investigation in illegal betting case.

SATYAM KESHARI vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: May 06, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant, Satyam Keshari, was arrested on January 21, 2026, in connection with Crime No. 05/2026 registered at P.S. Gandhinagar

Source reference: para. 1, 3

According to the prosecution, an FIR was filed following a complaint by Inspector Pradeep Jaiswal alleging that the applicant and co-accused Ujjwal Upadhyay operated illegal cricket betting activities

Source reference: para. 2

They were accused of procuring "mule" bank accounts from others to circulate proceeds derived from these illegal transactions

Source reference: para. 2

The applicant filed this First Bail Application after the charge-sheet was filed, seeking release on the ground of parity with co-accused Amit Mishra @Pahlu, who was granted bail on May 5, 2026

Source reference: para. 3
02

Issues

1. Whether the applicant is entitled to regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, based on the principle of parity and the completion of the investigation

Source reference: para. 1, 6
03

Law Applied

The court applied Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, which governs the High Court's power to grant regular bail

Source reference: para. 1

Sections 318(4), 317(4), 111, and 3(5) of the Bharatiya Nyaya Sanhita (BNS)

Source reference: para. 1

the court relied on the principle of parity in bail jurisprudence, which suggests that similarly situated accused persons should be treated equally regarding their liberty

Source reference: para. 3, 6

procedural requirements for bail conditions were informed by Sections 269 and 209 of the BNS and Sections 84, 351 of the BNSS

Source reference: para. 7
04

Reasoning

The court evaluated the application by weighing the nature of the allegations against the current status of the legal proceedings. It noted that the investigation was effectively complete as the charge-sheet had already been filed

Source reference: para. 6

High weight was given to the fact that a co-accused, Amit Mishra @Pahlu, involved in the same transaction, had already been granted bail by the same court just one day prior in MCRC No. 4138/2026

Source reference: para. 3, 6

Although the applicant had one previous criminal antecedent and had been in custody since January 21, 2026, the court determined that these factors, combined with the filing of the charge-sheet, justified the extension of parity to the applicant

Source reference: para. 6
05

Holding

The court allowed the bail application and ordered the release of Satyam Keshari on his furnishing a personal bond with two sureties

The grant of bail was made subject to strict conditions, including: (i) an undertaking not to seek unnecessary adjournments; (ii) mandatory presence on all trial dates; (iii) personal appearance during framing of charges and recording of statements under Section 351 BNSS; and (iv) a warning that violation of these terms would lead to proceedings under Sections 209 and 269 of the BNS

Source reference: para. 7
Chhattisgarh High Court

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SATYAM KESHARIvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · May 06, 2026

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