Chhattisgarh High Court
Criminal Procedure and EvidenceCriminal Law

Habitual offender status and prior NDPS antecedents preclude grant of regular bail despite claims of parity.

SHEKH JAVED vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: April 22, 20262 MIN READSOURCE JUDGMENT
Habitual offender status and prior NDPS antecedents preclude grant of regular bail despite claims of parity.. SHEKH JAVED vs STATE OF CHHATTISGARH. Chhattisgarh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant filed a second bail application under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023.

Source reference: p.1-2

He was arrested on 07.12.2024 in connection with Crime No. 1004/2024 involving the seizure of 150 narcotic ampoules (Buprenorphine and Rexogesic) from co-accused Srishti and Godavari Bai.

Source reference: p.1-2

The applicant’s first bail application was rejected on 06.11.2025 due to a criminal antecedent under the NDPS Act.

Source reference: p.2

The applicant argued for parity, noting that other co-accused had been granted bail by the High Court and Supreme Court, and claimed he was falsely implicated while already in custody for another matter.

Source reference: p.2-3

The State opposed the bail, citing the applicant’s status as a habitual offender.

Source reference: p.3
02

Issues

1. Whether the applicant is entitled to regular bail on the grounds of parity and the nature of the seized quantity, despite being a habitual offender with a pending NDPS case.

Source reference: p.3-4
03

Law Applied

The Court applied Sections 21, 22, and 29 of the Narcotic Drugs and Psychotropic Substances Act, 1985.

Source reference: p.1

It further relied on the legal principle established by the Supreme Court in Deepak Yadav v. State of Uttar Pradesh & Another (2022) 8 SCC 559, which dictates that bail may be denied or cancelled if the accused has significant previous criminal antecedents.

Source reference: p.3-4

The procedural framework was governed by Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023.

Source reference: p.1
04

Reasoning

The Court observed that this was the applicant’s second attempt at seeking bail and that no new grounds had been raised since the first rejection.

Source reference: p.2

Although the applicant argued that the contraband was less than commercial quantity and cited the release of co-accused persons on parity, the Court prioritized his criminal history.

Source reference: p.3

Applying the logic from Deepak Yadav, the Court reasoned that the applicant’s existing antecedent under the NDPS Act classifies him as a habitual offender.

Source reference: p.3-4

The existence of a pending trial for a similar offence outweighed the arguments for parity and the duration of his judicial custody.

Source reference: p.4
05

Holding

The Court answered the issue in the negative, holding that the applicant is not a fit candidate for regular bail due to his status as a habitual offender.

The second bail application was rejected.

Source reference: p.4

The trial court was directed to proceed with and conclude the trial expeditiously.

Source reference: p.4
06

Acts & Sections Cited

4 provisions across 2 statutes referred to in this judgment. Each provision opens on LawLens.

Bharatiya Nagarik Suraksha Sanhita, 20231

Narcotic Drugs and Psychotropic Substances Act, 19853

Chhattisgarh High Court

Original Court PDF

SHEKH JAVEDvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · April 22, 2026

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