Facts
The applicant filed a second bail application under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), seeking regular bail
Source reference: para. 1On 21.10.2024, police apprehended co-accused Shrishti Kurrey with 150 ampules of Buprenorphine
Source reference: para. 2Investigation led to co-accused Vikrant Sarkar, who was found with 22,752 Tramadol tablets and 4,000 Buprenorphine ampules
Source reference: para. 2The applicant was arrested on 24.10.2024 for allegedly being part of the supply chain
Source reference: para. 3His first bail application was rejected on 03.01.2025 due to the commercial quantity of the seizure
Source reference: para. 6The applicant moved this second application citing the principle of parity, as co-accused Naveen Idwani and Sandeep Kumar Chhabda (who has 11 criminal antecedents) were granted bail by the Supreme Court and High Court respectively
Source reference: para. 3-4Issues
1. Whether the applicant is entitled to regular bail on the grounds of parity and lack of criminal antecedents despite the recovery of a commercial quantity of contraband
Source reference: para. 3 & 6Law Applied
Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS) regarding bail
Source reference: para. 1Sections 21 and 22 of the Narcotics Drugs and Psychotropic Substances (NDPS) Act, 1985
Source reference: para. 1The doctrine of parity in bail jurisprudence, referencing the Supreme Court’s order in Naveen Idwani v. State (Criminal Appeal No. 332 of 2026) and its own previous order regarding co-accused Sandeep Kumar Chhabda
Source reference: para. 3-4Procedural conditions for bail were regulated under Sections 269, 84, and 209 of the Bharatiya Nyaya Sanhita (BNS) and Section 351 of the BNSS
Source reference: para. 8Reasoning
The court noted that while the initial rejection was based on the "huge commercial quantity" of the narcotics and the applicant’s alleged role in the supply chain, new circumstances warranted a reconsideration.
Source reference: para. 6The court observed that the Supreme Court had granted bail to co-accused Naveen Idwani on 19.01.2026
Source reference: para. 4the court highlighted that another co-accused, Sandeep Kumar Chhabda, was granted bail on 01.04.2026 despite having 11 criminal antecedents
Source reference: para. 4 & 6The court reasoned that since the present applicant has no criminal antecedents, his case stands on a "better" footing than that of the co-accused already released.
Source reference: para. 3 & 6Given that the charge-sheet has already been filed and the applicant has been in custody since October 2024, the court found continued detention unnecessary
Source reference: para. 3 & 6Holding
The lack of criminal antecedents and the grant of bail to similarly or worse-situated co-accused justified the relief
The court allowed the application and ordered the release of Ravishankar Markam on regular bail upon furnishing a personal bond with two sureties
Source reference: para. 7-8Case disposed
Source reference: para. 9Original Court PDF
RAVISHANKAR MARKAMvsSTATE OF CHHATTISGARH
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