Grant of regular bail for non-custodial interrogation offenses despite previous criminal antecedents and multiple pending trials.

The applicant, Saurabh Burande, filed three first bail applications (MCRC Nos. 1135/2026, 1140/2026, and 1148/2026) regarding three separate incidents of theft registered at P.S. GRP Raipur.

The allegations involve the theft of a mobile phone from a passenger on a train (Crime No. 50/2025).

The theft of gold and silver jewelry from a woman’s purse at a railway platform (Crime No. 128/2025).

The theft of a mobile phone from a pocket during train boarding (Crime No. 109/2025).

The applicant was arrested on 10.12.2025 following memorandum statements and alleged recoveries.

Charge-sheets have been filed, and the applicant has been in judicial custody since his arrest.

1. Whether the applicant is entitled to regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, considering his period of incarceration and the nature of the evidence.

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

Sections 303(2) (theft) and 3(5) (common intention) of the Bharatiya Nyaya Sanhita (BNS), 2023.

The Court observed the principle that bail should be considered where investigation is complete, the trial is expected to be prolonged, and the offences are triable by a competent Magistrate.

The Court evaluated the competing interests of the applicant’s liberty and the State's opposition based on the applicant's criminal history.

Although the State argued the applicant was a habitual offender with three antecedents, the Court noted that two of those cases were already disposed of and the third was at the stage of framing charges.

The Court balanced the "general nature" of the allegations and the fact that the cases relied heavily on recoveries—matters to be tested during trial—against the applicant’s four-month period of judicial custody since 10.12.2025.

Given that the charge-sheets were already filed and no further custodial interrogation was required, the Court determined that the conclusion of the trial would take considerable time, justifying the exercise of discretion in favor of the applicant.

The applicant is ordered to be released on bail upon furnishing a personal bond with two sureties, subject to strict conditions: he must not seek adjournments during witness testimony, must be present on all fixed dates, and must comply with procedural requirements under Sections 209, 269, and 351 of the BNSS; any abuse of liberty or failure to appear may result in the trial court revoking the bail.