Grant of bail for economic offenses under BNS on grounds of parity and completion of investigation.

The applicant, Leeladhar Prasad Sahu, filed four first bail applications seeking regular bail for four separate crimes involving alleged financial fraud

The prosecution alleged that the applicant and co-accused व्यक्तियों (individuals) lured multiple complainants into investing in share market trading schemes with promises of doubling or tripling their money, subsequently failing to return the principal or interest

Specifically, the complaints alleged misappropriation of Rs. 22,00,000 [para. 2], Rs. 39,10,000 [para. 3], Rs. 81,00,000 [para. 4], and Rs. 2,53,55,000

The applicant was arrested on March 18, 2026

The defense argued that the applicant was falsely implicated, that charge-sheets had been filed, and that several co-accused had already been granted bail by the High Court in the same crime numbers

1. Whether the applicant is entitled to regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, considering the filing of the charge-sheet and the grant of bail to co-accused persons.

The Court considered the provisions for regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023

It applied the principle of parity, noting that co-accused in the same crime numbers (470/2025, 170/2025, 430/2025, and 433/2025) had already been granted bail under various MCRC orders in 2025

The Court also observed the procedural status under the Bharatiya Nyaya Sanhita (BNS) for offences including Sections 318(4) (cheating), 316(5) (criminal breach of trust), 111 (organized crime), and 3(5) (joint liability)

The Court evaluated the gravity of the allegations involving multi-crore financial fraud against the procedural facts of the case

It noted that the investigation was effectively complete as the charge-sheet had been filed

Crucially, the Court found that the applicant had been in custody since March 18, 2026, and the trial was expected to take a considerable amount of time

The Court placed significant weight on the fact that several co-accused individuals, facing identical allegations in the same FIRs, had already been released on bail by the Court in 2025

While the State opposed bail on the grounds of the fraudulent nature of the share trading scheme, they could not dispute the grant of bail to co-accused

The Court held that given the period of incarceration and the fact that co-accused were already at liberty, the applicant was entitled to bail subject to furnishing a personal bond with two sureties

The release was made conditional upon the applicant’s regular attendance at trial, non-seeking of adjournments during witness testimony, and strict compliance with Sections 209, 269, and 351 of the BNSS/BNS to ensure the integrity of the judicial process