Grant of regular bail in share trading fraud based on parity and filing of charge-sheet.

The applicant, Leeladhar Prasad Sahu, was arrested in connection with four separate First Information Reports (FIRs): Crime Nos. 470/2025, 433/2025, 430/2025, and 170/2025

The prosecution alleged that the applicant and co-accused persons lured multiple complainants into investing significant sums of money—ranging from ₹2,00,000 to over ₹2.5 Crores—under the pretext of doubling or tripling the investment through share market trading

The complainants alleged that the principal amounts and promised returns were never repaid

The applicant has been in custody since March 18, 2026, and a charge-sheet has already been filed

1. Whether the applicant is entitled to regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, considering the nature of the allegations and the principle of parity with co-accused persons

Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 (corresponding to Section 439 of the CrPC) regarding the High Court's power to grant regular bail

Principle of parity, noting that several co-accused in the same crime numbers had already been granted bail by the High Court in previous orders (MCRC Nos. 6996/2025, 8595/2025, 7004/2025, and 9221/2025)

Sections 318(4) (Cheating), 316(5) (Criminal Breach of Trust), 111 (Organized Crime), and 3(5) (Common Intention) of the Bharatiya Nyaya Sanhita (BNS)

The Court evaluated the gravity of the allegations involving large-scale financial fraud against the procedural status of the case. It noted that the investigation was largely complete as the charge-sheet had been filed, reducing the risk of tampering with evidence

The Court observed that the applicant’s criminal history was limited to five related cases, in one of which he had already secured bail

The Court relied heavily on the fact that similarly situated co-accused individuals had been granted bail by coordinate benches in the same underlying transactions. Given that the trial was expected to take considerable time and the applicant had been in jail since March 2026, the Court reasoned that further incarceration was not warranted

The Court ordered the release of Leeladhar Prasad Sahu on bail upon furnishing a personal bond with two sureties, subject to strict conditions including: a prohibition on seeking unnecessary adjournments, mandatory appearance on all trial dates, and the threat of proceedings under Section 209 and 269 of the BNS/BNSS in case of non-compliance or misuse of liberty