Facts
The applicant, Chedilal Jatav, was arrested on 20.11.2025 in connection with Crime No. 619/2024 for allegedly firing a 12-bore double-barrel gun at the complainant and others during a multi-person altercation on 02.11.2024
Source reference: paras 2-3The applicant filed a second bail application under Section 483 of BNSS after his first application was withdrawn on 06.08.2025
Source reference: para 1The applicant moved for bail on the grounds that three key eye-witnesses (PW-1, PW-2, and PW-3) turned hostile during the trial
Source reference: para 4The State opposed the application, noting that one injured witness (Arti) has yet to be examined
Source reference: para 5Issues
1. Whether the applicant is entitled to the grant of regular bail under Section 483 of BNSS following a change in circumstances where material prosecution witnesses turned hostile?
Source reference: paras 4-7Law Applied
The court primarily applied Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, regarding the High Court's power to grant bail
Source reference: para 1It further considered the principle that prolonged pre-trial detention is an "anathema to the concept of liberty"
Source reference: para 7The court also assessed the necessity of imposing conditions to prevent witness tampering or absconding, consistent with standard criminal jurisprudence governing bail
Source reference: para 9Reasoning
The court evaluated the applicant’s prayer in light of the shifted evidentiary landscape.
Source reference: no citationAlthough the State argued that the testimony of one injured witness (Arti) was still pending, the court prioritized the fact that three material prosecution witnesses (Naveen Kumar, Bhagwan Singh, and Manish Kumar) had already been examined and did not support the prosecution’s case
Source reference: para 4, 7The court reasoned that since the trial was unlikely to conclude in the near future, continued detention would violate the applicant's right to liberty
Source reference: para 7It satisfied itself that the applicant, being a permanent resident of Bhind, was not a flight risk and could be released subject to stringent conditions to ensure the integrity of the remaining trial process
Source reference: paras 4, 8-9Holding
The Court allowed the bail application, directing the release of the applicant on a personal bond of Rs. 50,000/- with one solvent surety
The holding is conditioned upon the applicant cooperating with the trial, not committing further offences, and not attempting to influence witnesses
Source reference: para 9The Court concluded that the benefit of bail was warranted due to the hostile testimony of material witnesses and the anticipated delay in the trial’s conclusion
Source reference: para 7Original Court PDF
Chedilal Jatav v. The State of Madhya Pradesh [2026:MPHC-GWL:8877]
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