Grant of regular bail on the ground of parity following bail granted to co-accused by Supreme Court.

The applicant, Rajesh Mandhani, was arrested in connection with Crime No. 129/2025 involving organized cyber fraud

Based on information from the Cyber Crime Reporting Portal, it was discovered that 128 bank accounts at the Bank of Maharashtra, Raipur, were used as "mule accounts" to receive money obtained through cyber crimes

The applicant filed a first bail application (MCRC No. 8661 of 2025), which was rejected on merits on October 31, 2025

This is the applicant’s second bail application, moved after the filing of the charge-sheet and on the grounds that several co-accused persons, including Ishika Singh (by the Supreme Court) and others (by the High Court), had been granted regular bail

1. Whether the applicant is entitled to regular bail on the ground of parity and changed circumstances (filing of charge-sheet) following the rejection of his first bail application

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

Hon’ble Supreme Court granted bail to co-accused Ishika Singh in Criminal Appeal No. 4494/2025

The High Court had subsequently granted bail to co-accused Avinash Tandekar, Krishna Ghodesawar, and Jayant Ghosh in MCRC Nos. 148, 902, and 3319 of 2026 respectively

Section 269 and Section 209 of the Bharatiya Nyaya Sanhita (BNS) regarding non-appearance and misuse of liberty

The Court acknowledged that while the applicant’s first bail application was rejected on merits, subsequent developments created a valid ground for reconsideration

Specifically, the Court noted that the primary co-accused, Ishika Singh, had been granted bail by the Supreme Court, and three other co-accused were granted bail by the High Court in early 2026

The State Counsel’s objection—that the applicant facilitated organized cyber fraud through multiple bank accounts—was weighed against the fact that the charge-sheet had already been filed and that the State could not dispute the bail orders granted to the other co-accused

Consequently, applying the doctrine of parity, the Court reasoned that the applicant should not be further detained

The applicant was ordered to be released on a personal bond with two sureties, subject to conditions including: mandatory attendance on all trial dates, non-seeking of adjournments during witness testimony, and compliance with Section 269 of the BNS. Failure to comply would allow the trial court to treat the default as an abuse of liberty