Chhattisgarh High CourtCriminal LawCriminal Procedure and Evidence

Five Buffalo Calves In Crowded Pickup: Chhattisgarh HC Grants Bail To Driver, Cleaner And Alleged Buyer

DHARNIDHAR @ VINOD YADAVv.STATE OF CHHATTISGARH

Five Buffalo Calves In Crowded Pickup: Chhattisgarh HC Grants Bail To Driver, Cleaner And Alleged Buyer. DHARNIDHAR @ VINOD YADAV vs STATE OF CHHATTISGARH. Chhattisgarh High Court. LawLens
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In brief

The question

Whether the applicants should be released on regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, having regard to the allegations, their custody, the filing of the charge-sheet, and the likely duration of trial.

The court held

The Court allowed all three bail applications and directed that the applicants be released on execution of a personal bond of ₹50,000 each to the satisfaction of the trial Court.

It also directed

Bail was subject to conditions requiring them to remain available for police interrogation when required, not to influence persons acquainted with the case, and not to act prejudicially to a fair and expeditious trial.

The Court clarified that its observations were limited to deciding the bail applications and would not affect the trial Court’s independent determination on the merits.

01Facts

The applicants sought regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, in connection with Crime No. 216/2026, registered for offences under Sections 4, 6 and 10 of the Chhattisgarh Agricultural Cattle Preservation Act, 2004, Section 11(1)(d) of the Prevention of Cruelty to Animals Act, 1960, and Section 3(5) of the Bharatiya Nyaya Sanhita, 2023.

¶ 1

Police intercepted a pick-up truck carrying five buffalo calves in a congested manner.

¶ 2

Jaypal Sahu was driving and Rajendra Yadav was the conductor; during investigation, they named Dharnidhar @ Vinod Yadav as the purchaser of the cattle.

¶ 2

The applicants maintained that the cattle were being transported for agricultural purposes, that the charge-sheet had been filed, and that trial would take time.

¶ 3

The State opposed bail, alleging transportation for slaughter and pointing to two criminal antecedents of one applicant.

¶ 4

02Issues

i.Whether the applicants should be released on regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, having regard to the allegations, their custody, the filing of the charge-sheet, and the likely duration of trial.

¶ 1, 3–6

ii.Whether the criminal antecedents attributed to Jaypal Sahu warranted refusal of bail, notwithstanding that they were not of a similar nature.

¶ 3–6

03Law Applied

The Court considered its power to grant regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, in proceedings concerning alleged offences under Sections 4, 6 and 10 of the Chhattisgarh Agricultural Cattle Preservation Act, 2004, Section 11(1)(d) of the Prevention of Cruelty to Animals Act, 1960, and Section 3(5) of the Bharatiya Nyaya Sanhita, 2023.

¶ 1

In exercising its bail discretion, the Court considered the nature and gravity of the allegations, the applicants’ antecedents, the filing of the charge-sheet, the period spent in custody, and the likely time required to conclude the trial.

¶ 6

No precedent was cited.

Provisions in the judgment · 3 · Linked ones open on LawLens

Bharatiya Nagarik Suraksha Sanhita, 2023 Section 483

Prevention of Cruelty to Animals Act, 1960 Section 11

Bharatiya Nyaya Sanhita, 2023 Section 3

04Reasoning

The Court weighed the allegations and the State’s opposition against the applicants’ custody since 23 and 24 September 2026, the filing of the charge-sheet, and the likelihood of delay in concluding the trial.

¶ 3–6

It also considered that Dharnidhar and Rajendra had no criminal antecedents, while Jaypal’s two antecedents were not of a similar nature.

¶ 6

On that overall assessment, the Court found the applicants entitled to bail.

¶ 6

05Holding

The Court allowed all three bail applications and directed that the applicants be released on execution of a personal bond of ₹50,000 each to the satisfaction of the trial Court.

¶ 7

Bail was subject to conditions requiring them to remain available for police interrogation when required, not to influence persons acquainted with the case, and not to act prejudicially to a fair and expeditious trial.

¶ 7

The Court clarified that its observations were limited to deciding the bail applications and would not affect the trial Court’s independent determination on the merits.

¶ 7
Chhattisgarh High Court

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DHARNIDHAR @ VINOD YADAVvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · November 03, 2026

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