Chhattisgarh High Court

Grant of bail as custodial interrogation is unnecessary following charge-sheet filing and absence of criminal antecedents.

MANISH KUMAR RAMTEKE vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: April 27, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant, Manish Kumar Ramteke, sought regular bail after being arrested on December 26, 2025, for offenses under Sections 109 (Possession of offensive weapon) and 3(5) (Joint liability) of the Bharatiya Nyaya Sanhita (BNS).

Source reference: para 1, 8

The prosecution alleged that on December 24, 2025, the applicant and a co-accused confronted the complainant over a prior dispute, during which the applicant allegedly assaulted the complainant with a hand/thermocol cutter, while the co-accused attempted a knife attack.

Source reference: para 2, 4

The applicant argued false implication, stating he arrived after the incident and that the complainant's party were the aggressors.

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) considering the nature of the allegations and the period of incarceration.

Source reference: para 1, 6
03

Law Applied

Section 483 of the BNSS (corresponding to Section 439 of the CrPC) regarding the discretionary power of the High Court to grant bail.

Source reference: para 1

It considered the principles of custodial necessity, noting that bail is a rule when investigation is complete and the charge-sheet is filed.

Source reference: para 6

Sections 109 and 3(5) of the BNS regarding the substantive offenses charged.

Source reference: para 1

Section 269 and 351 of the BNSS regarding trial procedures and personal attendance.

Source reference: para 8
04

Reasoning

While the State highlighted the "grievous" nature of the injuries per a query report, the Court observed that the initial Medico-Legal Certificate (MLC) did not explicitly specify such nature.

Source reference: para 4, 6

The Court emphasized that the investigation was complete, the charge-sheet had been filed, and thus no further custodial interrogation was required.

Source reference: para 6

The Court noted the applicant's lack of criminal antecedents and the fact that he had been in custody since late 2025, concluding that prolonged detention pending a trial that "is likely to take considerable time" was unwarranted.

Source reference: para 6
05

Holding

The applicant deserved to be enlarged on bail as no further custody was necessary for the conclusion of the trial.

The Court allowed the bail application. The applicant was ordered to be released upon furnishing a personal bond with two sureties, subject to conditions including mandatory attendance at trial and a prohibition against seeking unnecessary adjournments. The trial court was directed to treat any breach of these conditions as an abuse of liberty.

Source reference: para 8(i)-(iv)
Chhattisgarh High Court

Original Court PDF

MANISH KUMAR RAMTEKEvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · April 27, 2026

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