01Facts
The applicant sought regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, in a case alleging fraudulent transactions of approximately ₹2 crore from the complainant’s Jan Dhan account.
¶ 1The prosecution alleged that the account’s registered mobile number was changed and that withdrawals and digital transactions followed.
¶ 1The applicant was charged under Sections 318, 3(5), 338, 336(3) and 340(2) of the Bharatiya Nyaya Sanhita, 2023, and Sections 66C and 66D of the Information Technology Act, 2000.
¶ 1He had been in custody since 15 December 2025.
¶ 1His earlier bail application was dismissed on merits on 1 June 2026.
¶ 1In support of the present application, he relied, among other things, on completion of the investigation, the filing of the charge-sheet, and the claimed hostility of material witnesses.
¶ 1The State opposed bail and submitted that no sufficient change in circumstances had been shown.
¶ 1–402Issues
i.Whether the applicant had established sufficient grounds for grant of regular bail under Section 483 of the BNSS.
¶ 1, 5ii.Whether any substantial change in circumstances since the dismissal of the applicant’s earlier bail application justified reconsideration of bail.
¶ 1, 4–503Law Applied
The application was considered under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, which provides the relevant basis for the High Court’s consideration of regular bail.
¶ 1The Court also applied the principle that a subsequent bail application following an earlier rejection requires consideration of whether a substantial change in circumstances has been demonstrated; it found that none had been shown.
¶ 5Provisions in the judgment · 6 · Linked ones open on LawLens
Bharatiya Nagarik Suraksha Sanhita, 2023 Section 483
Bharatiya Nyaya Sanhita, 2023 Section 318Section 3Section 338Section 336Section 340
04Reasoning
The Court considered the case diary and the material on record, including the nature and gravity of the alleged financial offences.
¶ 3–5Although the applicant relied on completion of the investigation and other grounds, the Court concluded that those submissions did not establish sufficient grounds for bail or a substantial change in circumstances after the earlier merits-based rejection.
¶ 3–5It therefore declined to exercise its discretion in the applicant’s favour at that stage.
¶ 3–505Holding
The Court held that no sufficient ground for regular bail had been made out and that no substantial change in circumstances warranted reconsideration of the earlier rejection.
¶ 5The second bail application was dismissed.
¶ 5Original Court PDF
Praveen JaiswalvsThe State Of Madhya Pradesh
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