Madhya Pradesh High Court

Grant of bail for non-commercial quantity of MDMA where prosecution witnesses turned hostile and no criminal antecedents existed.

Alfaiz Sheikh v. The State of Madhya Pradesh [M.Cr.C. No. 10273 of 2026]

Madhya Pradesh High Court2 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant was intercepted by the police on September 15, 2025, based on secret information.

Source reference: para. 4

A personal search resulted in the recovery of 40.5 grams of MD Drugs from his pant pocket.

Source reference: para. 4

Consequently, Crime No. 455/2025 was registered under Sections 8/22 and 29 of the NDPS Act at P.S. Agar Malwa.

Source reference: no citation

The applicant has been in judicial custody since his arrest on September 15, 2025.

Source reference: para. 1

A previous bail application (M.Cr.C. No. 54454/2025) was dismissed as withdrawn on November 26, 2025.

Source reference: para. 1

The applicant moved this second bail application after the examination of material prosecution witnesses Ravi (PW.1) and Gajab Singh (PW.2).

Source reference: para. 1, 2
02

Issues

Whether the applicant is entitled to regular bail under Section 483 of BNSS 2023, considering the nature of the contraband seized and the progress of the trial.

Source reference: para. 1, 6
03

Law Applied

The Court applied Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (corresponding to Section 439 of the Cr.P.C.) regarding the grant of regular bail.

Source reference: para. 1

It further considered Sections 8, 22, and 29 of the Narcotic Drugs and Psychotropic Substances (NDPS) Act, 1985.

Source reference: para. 1

The court also referenced Section 346 of the BNSS (corresponding to Section 309 of the Cr.P.C.) regarding the timely examination of witnesses.

Source reference: para. 7(5)
04

Reasoning

The Court noted that while the contraband was allegedly recovered from the applicant's pocket, the quantity did not fall within the "commercial" category.

Source reference: para. 2, 4

It observed that the applicant is a 20-year-old labourer with no reported criminal antecedents and has already undergone six months of incarceration.

Source reference: para. 2, 3, 5

The Court found that since the material independent seizure witnesses (PW.1 and PW.2) have already been examined, the risk of tampering with evidence or influencing witnesses is minimal.

Source reference: para. 2, 5

Given the applicant's socio-economic status and the fact that the trial is expected to take significant time, the Court determined there was no "compelling reason" to continue his incarceration.

Source reference: para. 5

The Court clarified that the veracity of search and seizure procedures remains a matter for trial merits.

Source reference: para. 4
05

Holding

The High Court allowed the application and directed the release of the applicant on bail upon furnishing a personal bond of Rs. 50,000/- with one surety of the same amount.

The bail is subject to conditions including: (i) regular appearance at hearings; (ii) refraining from committing similar offences; (iii) no tampering with evidence or threatening witnesses; and (iv) compliance with Section 346 of BNSS regarding witness examination.

Source reference: para. 7

The Court held that there was no likelihood of recidivism or fleeing from justice.

Source reference: para. 5
Madhya Pradesh High Court

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Alfaiz Sheikh v. The State of Madhya Pradesh [M.Cr.C. No. 10273 of 2026]

Madhya Pradesh High Court

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