Grant of Bail on Grounds of Parity and Completion of Investigation in Organized Liquor Syndicate Case

The applicant, Dhanaram Sahu, was arrested on June 4, 2026, in connection with Crime No. 25/2026 for the alleged illegal manufacture and sale of "Deshi Masala Romiyo" (illicit country liquor).

The prosecution alleged that an organized syndicate was involved in manufacturing illicit liquor, based on the memorandum statement of co-accused Nitesh Ratre.

The applicant sought regular bail, contending that his name was not mentioned in the FIR or the final report, no recovery of liquor was made from him, and he was implicated solely on the basis of a co-accused's statement.

The charge sheet has been filed, and a co-accused, Lokesh @ Lucky Ahuja, had previously been granted bail.

1. Whether the applicant is entitled to regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, considering the lack of direct evidence and the principle of parity with a co-accused.

Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), which governs the grant of regular bail.

Section 34(2) of the Chhattisgarh Excise Act regarding the possession of illicit liquor and Section 111 of the Bharatiya Nyaya Sanhita (BNS) relating to organized crime.

The Court also considered the principle of parity in bail matters, observing that a similarly situated co-accused had already been granted relief.

The Court examined the nature of the allegations and the period of the applicant's detention since June 4, 2026.

It noted that the applicant's implication rested on a memorandum statement of a co-accused rather than direct recovery.

The Court observed that the charge sheet had already been filed, and since the trial was likely to take a significant amount of time to conclude, continued incarceration was not warranted.

Crucially, the Court applied the principle of parity, noting that co-accused Lokesh @ Lucky Ahuja had been granted bail by the same court on April 8, 2026, in M.Cr.C. No. 3133/2026.

The applicant was directed to be released upon furnishing a personal bond with two sureties, subject to specific conditions: (i) an undertaking not to seek unnecessary adjournments; (ii) mandatory presence on trial dates per Section 269 BNS; (iii) liability under Section 209 BNS for misuse of liberty; and (iv) mandatory personal appearance for framing of charges and recording of statements under Section 351 BNSS.