Chhattisgarh High Court

Grant of regular bail to female accused in financial fraud case parity with co-accused granted bail.

Smt. Aarti Jangde v. State of Chhattisgarh [2026:CGHC:11479]

Chhattisgarh High CourtJUDGMENT: no citation2 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant filed her first bail application seeking regular bail following her arrest on January 7, 2026.

Source reference: para. 1, 3

The prosecution alleged that the applicant, while operating the Shakhi Credit Sahakari Samiti Maryadit (Shakhi Bank) in Masturi, cheated various beneficiaries of ₹3,13,883 and the complainant, Parvati Kesharwani, of ₹27,00,000 under the pretext of financial dealings.

Source reference: para. 2

An FIR was registered at Police Station Seepat for offences under Sections 420 and 34 of the Indian Penal Code.

Source reference: para. 1, 2

The applicant contended she was falsely implicated and noted that a co-accused, Smt. Hemlata Sahu, had already been granted anticipatory bail.

Source reference: para. 3
02

Issues

Whether the applicant is entitled to regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, considering her gender, the filing of the charge-sheet, and the grant of bail to a co-accused.

Source reference: para. 1, 6
03

Law Applied

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

Source reference: para. 1

The court also considered Sections 420 (cheating) and 34 (common intention) of the Indian Penal Code (IPC) under which the applicant was charged.

Source reference: para. 1

The court referenced procedural requirements for bail conduct under Sections 269 (non-appearance), 84 (proclamation for person absconding), 209 (failure to appear in court), and 351 (accused's statement) of the BNSS.

Source reference: para. 8
04

Reasoning

The court evaluated the gravity of the offense, which involved substantial financial misappropriation from multiple victims.

Source reference: para. 6

The court balanced these allegations against several mitigating factors: the applicant is a woman, she had been in detention since January 7, 2026, and the charge-sheet had already been filed, indicating that further custodial interrogation might not be necessary.

Source reference: para. 3, 6

The court specifically noted that a co-accused, Smt. Hemlata Sahu, had been granted anticipatory bail on February 11, 2026, and that the applicant had no prior criminal antecedents.

Source reference: para. 3, 6

Consequently, the court determined that the transition of the case to trial, which would take time to conclude, justified the applicant's release on bail.

Source reference: para. 3, 6
05

Holding

The High Court allowed the bail application and directed the release of Smt. Aarti Jangde upon furnishing a personal bond with two sureties.

The court held that the applicant deserved bail based on her gender, the principle of parity with the co-accused, and her clean criminal record.

Source reference: para. 6

The release is subject to strict conditions, including an undertaking not to seek unnecessary adjournments and mandatory presence during key trial stages such as the framing of charges and recording of statements under Section 351 of the BNSS.

Source reference: para. 8
Chhattisgarh High Court

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Smt. Aarti Jangde v. State of Chhattisgarh [2026:CGHC:11479]

Chhattisgarh High Court · no citation

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