Grant of regular bail for abetment of suicide despite extensive criminal antecedents and video evidence.

On January 2, 2026, Naresh Sahu committed suicide by hanging at his residence in Village Bampara.

Prior to his death, the deceased recorded and uploaded a video on social media alleging continuous physical and mental harassment by the applicant.

Following a merg inquiry under Section 194 of the BNSS, Crime No. 05/2026 was registered for abetment of suicide.

The applicant, who was already in judicial custody for a separate offense (Crime No. 719/2025), was arrested in the present case via production warrant on January 13, 2026.

The applicant sought regular bail, noting that while he has eight prior criminal involvements, he has been granted bail in all previous matters.

1. Whether the applicant is entitled to regular bail under Section 483 of the BNSS, 2023, considering his criminal antecedents and the allegations of abetment of suicide.

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

Section 108 of the Bharatiya Nyaya Sanhita (BNS), which defines and punishes the abetment of suicide.

Section 269 of the BNS regarding non-appearance before the court and Section 84 of the BNSS regarding proclamations for absconding persons.

The Court balanced the gravity of the offense—specifically the existence of a suicide video naming the applicant—against procedural factors and the applicant's history.

While the State opposed bail citing the deceased’s allegations of mental and physical harassment, the Court observed that the investigation was nearing completion and a charge-sheet had already been filed before the Chief Judicial Magistrate.

Regarding the applicant's eight criminal antecedents, the Court noted that the applicant had already been granted bail in all those previous cases.

Considering the period of detention since January 13, 2026, and the fact that the trial would take time to conclude, the Court determined that further custody was not requisite, provided stringent conditions were imposed to ensure the applicant's presence during trial.

The holding was conditioned upon the applicant furnishing a personal bond with two sureties and adhering to strict conduct requirements, including attending all trial dates for charge framing and evidence, and not seeking unnecessary adjournments.

The trial court was authorized to treat any default as an abuse of liberty and proceed under Section 209 or 269 of the BNS as applicable.