Grant of bail on grounds of parity and filing of charge-sheet in land forgery case.

The applicant, Komal Chand Sahu, was arrested on 11.12.2025 in connection with Crime No. 154/2025 at Police Station Kumhari.

The prosecution alleged that the applicant and co-accused persons prepared forged documents to illegally record their names in revenue records for government land and subsequently used those documents to obtain Kisan Credit Card (K.C.C.) loan facilities from a bank.

A charge-sheet has been filed, and the applicant sought regular bail on the grounds of parity with a co-accused and the fact that he was already granted bail in a related matter arising from the same cause of action.

Whether the applicant is entitled to the grant of regular bail under Section 483 of the BNSS, 2023, considering the nature of the offense and the principle of parity.

The Court applied Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), which governs the power of the High Court to grant bail.

The Court also considered the doctrine of parity, referencing the prior grant of bail to an identically situated co-accused, Amit Kumar Maurya, in MCRC No. 1900 of 2026.

Additionally, the Court noted the application of Sections 318(4), 336(3), 338, 347, and 112(2) of the Bharatiya Nyaya Sanhita (BNS), 2023, concerning cheating, forgery, and criminal conspiracy.

The Court evaluated the gravity of the allegations involving the forgery of government land records and bank fraud against the applicant's period of detention since 11.12.2025.

The Chief Justice observed that although the allegations were serious, a charge-sheet had already been filed and the trial was expected to take considerable time.

Crucially, the Court applied the principle of parity, noting that co-accused Amit Kumar Maurya had been granted bail.

Regarding the applicant’s criminal antecedent (Crime No. 201/2025), the Court found it significant that the applicant had already been granted bail in that case as it arose from the same cause of action.

Consequently, the Court determined that continued detention was not warranted.

The Court answered the issue in the affirmative, holding that the applicant's detention period and the parity with the co-accused justified his release.

The release was made subject to strict conditions, including mandatory appearance at trial dates under Section 269 of the BNS and a prohibition against seeking unnecessary adjournments.