Chhattisgarh High Court

Grant of Regular Bail on Ground of Parity for Offences Under Bharatiya Nyaya Sanhita

MOHAMMAD ILIYAS vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: April 24, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant, Mohammad Iliyas, was arrested in connection with Crime No. 79/2025 for allegedly depositing ₹27,27,556—obtained through fraudulent means—into various bank accounts and engaging in the concealment of said property

Source reference: p. 2, para. 2

Following the investigation, a charge-sheet was filed at Police Station Ganj Range Cyber Raipur

Source reference: p. 2, para. 2

The applicant moved this first bail application under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), seeking parity with co-accused Bhagawat Prasad Shukla, Ayush Pandey, and Bhanu Pratap Sen, all of whom had previously been granted bail by either the Supreme Court or the High Court

Source reference: p. 2, para. 3
02

Issues

1. Whether the applicant is entitled to regular bail on the grounds of parity and the completion of the investigation

Source reference: p. 3, para. 6
03

Law Applied

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

Source reference: p. 1, para. 1

The court relied on the Principle of Parity, noting that similarly situated co-accused had been granted relief. It specifically referenced the Supreme Court’s order in Bhagawat Prasad Shukla v. State (SLP Crl. No. 20364/2025) and its own previous orders in Ayush Pandey v. State (MCRC No. 1586/2025) and Bhanu Pratap Sen v. State (MCRC No. 2498 of 2026)

Source reference: p. 2, para. 3; p. 3, para. 6

Requirements for the accused’s presence during trial proceedings were framed under Sections 269, 84, 209, and 351 of the Bharatiya Nyaya Sanhita (BNS)

Source reference: p. 4, para. 7
04

Reasoning

The Court analyzed the facts and circumstances of the case, the nature of the allegations, and the procedural status, noting that the charge-sheet had already been filed

Source reference: p. 3, para. 6

The primary factor in the Court's reasoning was the principle of parity; since three co-accused (Shukla, Pandey, and Sen) facing similar allegations had already been released on bail by superior and coordinate benches, the Court found no justification for the continued detention of the applicant

Source reference: p. 3, para. 6

The State’s opposition was noted, but the State counsel could not dispute that the co-accused were already at liberty

Source reference: p. 2-3, para. 4
05

Holding

The Court allowed the bail application, holding that the applicant deserves to be released on the ground of parity

The Court ordered the release of Mohammad Iliyas on a personal bond with two sureties, subject to several conditions: (i) no seeking of unnecessary adjournments, (ii) mandatory appearance on trial dates, and (iii) compliance with trial milestones such as framing of charges and recording of statements

Source reference: p. 3-4, para. 7

Default in these conditions grants the trial court liberty to treat such actions as an abuse of bail

Source reference: p. 4, para. 7(iv)
Chhattisgarh High Court

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MOHAMMAD ILIYASvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · April 24, 2026

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