Grant of first regular bail for Section 420 IPC offence where charge-sheet is filed and accused has custody parity.

The applicant filed a First Bail Application under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, seeking regular bail.

The prosecution alleged that in 2022, the applicant induced the complainant and his relatives to invest ₹63,50,000 in property deals, promising a 5% monthly profit for 20 months plus the principal return.

While the applicant returned ₹30,95,000, he allegedly defaulted on the remaining ₹32,55,000, leading to a complaint and FIR under Section 420 IPC.

The applicant has been in custody since September 3, 2025, and a charge-sheet has already been filed.

1. Whether the applicant is entitled to regular bail considering the completion of the investigation (filing of charge-sheet) and his prior bail history in related matters.

Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (formerly Section 439 of the CrPC) regarding regular bail.

Principles of Liberty and Trial duration, particularly in financial offenses under Section 420 of the Indian Penal Code.

Procedural safeguards regarding the conduct of a bailed accused, incorporating duties now codified under Sections 269, 84, 209, and 351 of the Bharatiya Nagarya Sanhita (BNS) and BNSS.

The Court analyzed the gravity of the allegations alongside several mitigating factors. It noted a significant delay in lodging the FIR, which the applicant argued suggested an afterthought.

Although the applicant had six criminal antecedents, the Court observed that he had already been granted bail by the same High Court in four other cases (MCRC Nos. 10386/2025, 796/2026, 1669/2026, and 2759/2026).

The Court reasoned that since the charge-sheet was filed and the applicant had remained in jail for over seven months (since 03.09.2025), the continued incarceration was unnecessary as the trial was likely to be prolonged.

The holding emphasized that the trial's conclusion would take time and the investigation was complete. The Court imposed strict conditions, including a prohibition on seeking unnecessary adjournments, mandatory presence during key trial stages, and warnings that failure to appear would trigger proceedings under Section 209 of the BNS and Section 84 of the BNSS.