Intermediate quantity narcotics seizure and lack of NDPS antecedents justify bail despite other pending criminal cases.

The applicant was arrested on February 6, 2026, in connection with Crime No. 132/2026 at Sakri Police Station after 1.483 kgs of Ganja were allegedly seized from his possession following a secret tip

The applicant filed this first bail application under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), asserting false implication, non-compliance with Section 42 of the NDPS Act regarding search warrants, and noting that the quantity seized was "intermediate" rather than "commercial"

The State opposed the bail, citing five criminal antecedents under the Arms Act, IPC, and Excise Act, and confirming that the charge-sheet had already been filed

Whether the applicant is entitled to regular bail under Section 483 of the BNSS considering the seized quantity of contraband is less than commercial quantity and he has no prior NDPS antecedents.

Section 20(B) of the Narcotic Drugs and Psychotropic Substances Act, 1985, regarding the possession of cannabis

Section 37 of the NDPS Act, noting that the statutory bar for bail applies specifically to "commercial quantities" (defined as more than 20 kgs for Ganja)

Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), which pertains to the power of the High Court to grant bail

Sections 84, 209, 269, and 351 of the BNSS and the Bharatiya Nyaya Sanhita (BNS) for the imposition of bail conditions and trial attendance

The Court observed that while the applicant possesses five criminal antecedents from 2022 to 2025, none of these offenses fall under the NDPS Act

Crucially, the court found that the recovery of 1.483 kgs of Ganja constitutes an "intermediate quantity," which is significantly lower than the 20 kg threshold required to trigger the stringent regular bail restrictions under Section 37 of the NDPS Act

Because the investigation was complete and the charge-sheet had been filed, the Court reasoned that further custodial detention was unnecessary, provided that strict conditions were imposed to ensure the applicant's presence during trial and to prevent the abuse of liberty

The Court allowed the bail application and ordered the release of Avdhesh Verma on a personal bond with two sureties, subject to specific conditions including a prohibition on seeking unnecessary adjournments and mandatory attendance at trial stages.