Grant of Regular Bail on Grounds of Parity and Completion of Investigation in Financial Fraud Cases

The applicant, Leeladhar Prasad Sahu, sought regular bail across four connected applications (MCRC Nos. 3365, 3891, 3534, and 3467 of 2026) concerning multiple FIRs registered at Police Stations Kasdol and Gidhori Tundra

The prosecution alleged that the applicant, along with co-accused persons, induced several complainants to invest large sums of money—totaling crores of rupees—into share market trading under the pretext of doubling or tripling their investments within specific timeframes

While the money was deposited into various bank accounts (including those of co-accused Ramnarayan and Devnarayan Sahu), the promised returns and principal amounts were never repaid

The applicant was arrested on March 18, 2026

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

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

The substantive offences were registered under Sections 318(4) (cheating), 316(5) (criminal breach of trust), 318(3), 3(5) (common intention), and 111 (organized crime) of the Bharatiya Nyaya Sanhita (BNS)

The court also relied on the principle of parity in bail, observing that co-accused persons in the same crime numbers had already been granted bail by coordinate benches

The Court balanced the gravity of the allegations involving financial fraud against the procedural status of the case. It noted that the investigation was largely complete as the charge-sheet had already been filed

Crucially, the Court observed that the applicant had already been granted bail in one of the five pending cases against him (MCRC No. 3864/2026)

Furthermore, the Court evaluated the "Rule of Parity," noting that co-accused persons in all four relevant Crime Nos. (470/2025, 433/2025, 430/2025, and 170/2025) had been granted bail between October and December 2025

Given that the applicant had been in custody since March 2026 and the trial was expected to take considerable time, the Court found no justification for continued incarceration

The High Court allowed the bail applications, directing the release of Leeladhar Prasad Sahu on a personal bond with two sureties. The bail was made subject to strict conditions, including a prohibition on seeking unnecessary adjournments, mandatory attendance at trial under Section 269 of BNS, and personal appearance during specific trial stages like the framing of charges and recording of statements under Section 351 of BNSS