Individual with no criminal antecedents granted bail following completion of investigation and filing of charge-sheet.

The applicant, Nilesh Sahu, was arrested on 28.01.2026 in connection with Crime No. 18/2026 registered at P.S. Mujgahan for allegedly stealing a vehicle

According to the prosecution, the complainant’s vehicle was stolen from outside his godown on 24.01.2026, leading to an FIR against unknown persons on 25.01.2026

Following an investigation, a charge sheet was filed before the trial court

The applicant moved this first bail application under Section 483 of the Bhartiya Nagarik Suraksha Sanhita (BNSS), 2023, contending that the investigation is complete and further custodial interrogation is unnecessary

1. Whether the applicant is entitled to the grant of regular bail under Section 483 of the BNSS, 2023, considering the completion of the investigation and his lack of criminal antecedents.

Section 483 of the Bhartiya Nagarik Suraksha Sanhita (BNSS), 2023, regarding the power of the High Court to grant bail

settled principles of criminal jurisprudence which dictate that once an investigation is complete and a charge-sheet is filed, an accused should not be detained in judicial custody indefinitely, particularly when the trial is expected to take time

Section 269 of the Bharatiya Nyaya Sanhita (BNS) regarding non-appearance, Section 84 of the BNSS regarding proclamations for absconding persons, and Section 351 of the BNSS regarding the recording of accused statements

The Court evaluated the necessity of continued incarceration against the backdrop of the completed investigation. It noted that the charge-sheet had already been submitted before the competent court, meaning all evidence relied upon by the prosecution had been collected, thus rendering custodial interrogation redundant

The Court placed significant weight on the fact that the applicant had no prior criminal record and had been in custody since 28.01.2026. Reasoning that the conclusion of the trial would likely take considerable time, the Court determined that further detention was unjustified and that the applicant's liberty should be restored subject to stringent conditions to ensure his participation in the trial

The applicant, Nilesh Sahu, was ordered to be released on regular bail upon furnishing a personal bond with two sureties, subject to several conditions: (i) he must not seek adjournments during witness presence; (ii) he must attend every trial date or face proceedings under Section 269 BNS; (iii) if he absconds during a proclamation, proceedings under Section 209 BNS will be initiated; and (iv) he must be personally present for the opening of the case, framing of charges, and recording of his statement under Section 351 BNSS