Grant of regular bail in property investment fraud case where charge-sheet is filed.

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

He was arrested on 04.12.2025 in connection with Crime No. 279/2025 at P.S. Kawardha for allegedly committing an offence under Section 420 of the Indian Penal Code (IPC).

The complainant, Lokesh Baghel, alleged that the applicant induced him to invest ₹11,20,000 in real estate on the promise of doubling the amount in 20 months, out of which ₹7,90,000 remained unpaid.

The applicant argued that the FIR was an afterthought due to long delay and noted that he had already secured bail in four other criminal cases of similar nature.

The State opposed the bail, citing the applicant’s six prior criminal antecedents.

Whether the applicant is entitled to regular bail considering his period of incarceration, the nature of the allegations, and his criminal history.

Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, regarding the High Court's power to grant bail.

Section 420 of the Indian Penal Code, 1860, concerning cheating and dishonestly inducing delivery of property.

Sections 84, 209, 269, and 351 of the BNSS to impose conditions for ensuring the applicant's presence during trial and to prevent the abuse of the liberty of bail.

The Court balanced the gravity of the allegations against the procedural status of the case.

It observed that although the applicant has a significant criminal history of six antecedents, he had already been granted bail by the same High Court in four of those matters (MCRC Nos. 10386/2025, 796/2026, 1669/2026, and 2759/2026).

The Court took particular note of the delay in lodging the FIR, the fact that the charge-sheet had already been filed, and the applicant's incarceration since December 2025.

Reasoning that the trial was likely to take a considerable amount of time, the Court determined that continued detention was unnecessary, provided stringent conditions were imposed to ensure the applicant’s cooperation with the judicial process.

The holding was conditioned upon the applicant not seeking unnecessary adjournments, appearing personally on key trial dates (framing of charges and recording of statements), and complying with appearance requirements under the BNSS. Failure to comply would allow the trial court to treat the default as an abuse of liberty and proceed in accordance with law.