Chhattisgarh High Court

Grant of regular bail on the ground of parity for alleged insurance fraud under BNS.

BALMUKUND JANGHEL vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: April 28, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicants filed first bail applications following their arrest on February 2, 2026, in connection with Crime No. 294/2025.

Source reference: para. 2, 4

The prosecution alleged that the applicants, in connivance with officials and insurance agents, dishonestly obtained over ₹25 lakhs under the Pradhan Mantri Fasal Beema Yojana (2024–2025).

Source reference: para. 3

It was alleged that they falsely claimed cultivation and loss of a chickpea crop on land where banana crops were actually grown.

Source reference: para. 3

The applicants contended they were falsely implicated without direct evidence of forgery and sought parity with a co-accused, Parmeshwar Sahu, who was previously granted bail.

Source reference: para. 4
02

Issues

1. Whether the applicants are entitled to regular bail under Section 483 of the Bhartiya Nagarik Suraksha Sanhita (BNSS), 2023, based on the principle of parity and the stage of the trial.

Source reference: para. 2, 7
03

Law Applied

The Court considered the provisions for regular bail under Section 483 of the Bhartiya Nagarik Suraksha Sanhita (BNSS), 2023.

Source reference: para. 2

It applied the principle of parity in bail jurisprudence, referencing its own prior order in Parmeshwar Sahu v. State of Chhattisgarh (MCRC No. 3806/2026), which involved identical facts from the same incident.

Source reference: para. 4, 7

The Court also noted the penal provisions under Sections 316(5), 318(4), 336(2), 336(3), 338, 340(2), and 61(2) of the Bharatiya Nyaya Sanhita (BNS), 2023, and Section 269 of the BNS regarding non-attendance.

Source reference: para. 2, 8
04

Reasoning

The Court analyzed the gravity of the allegations involving the fraudulent misappropriation of insurance funds against the specific circumstances of these applicants.

Source reference: para. 7

It observed that the applicants had no prior criminal record and had been incarcerated since February 2, 2026.

Source reference: para. 4, 7

Critically, the Court found that the case against the present applicants was identical to that of co-accused Parmeshwar Sahu, who had already been released on bail.

Source reference: para. 5, 7

Given that the charge-sheet had already been filed and the trial was expected to be protracted, the Court determined that the applicants satisfied the criteria for discretionary relief based on parity and the lack of a need for further custodial investigation.

Source reference: para. 7
05

Holding

The court held that the applicants were entitled to release on the ground of parity.

The High Court allowed the bail applications. The applicants were ordered to be released on furnishing personal bonds and two sureties each, subject to conditions: they must not seek unnecessary adjournments, must attend all court proceedings under risk of Section 269 BNS proceedings, and must appear personally for framing of charges and recording of statements under Section 351 BNSS.

Source reference: para. 8
Chhattisgarh High Court

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BALMUKUND JANGHELvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · April 28, 2026

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