Chhattisgarh High Court
Criminal Procedure and EvidenceCriminal Law

Multiple similar excise-offence antecedents justified denial of regular bail.

ANITA BANJARE vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: September 30, 20261 MIN READSOURCE JUDGMENT
Multiple similar excise-offence antecedents justified denial of regular bail.. ANITA BANJARE vs STATE OF CHHATTISGARH. Chhattisgarh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant sought regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, after her arrest in Crime No. 223/2026, registered under Section 34(2) of the Chhattisgarh Excise Act, 1915.

Source reference: para. 1

The prosecution alleged that a search of her house resulted in the seizure of 10 litres of handmade raw mahua liquor and 7.200 litres of country-made plain liquor.

Source reference: para. 1–2

The applicant had been in custody since 14 July 2026, and the charge-sheet had been filed.

Source reference: para. 3–4

The State opposed bail, relying on four prior Excise Act cases: two disposed of and two pending.

Source reference: para. 3–4
02

Issues

Whether the applicant should be released on regular bail under Section 483 BNSS, having regard to the allegations, the seizure, and her criminal antecedents.

Source reference: para. 1, 5–6
03

Law Applied

Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, provides the basis for the High Court’s consideration of an application for regular bail.

Source reference: para. 1

The alleged offence was punishable under Section 34(2) of the Chhattisgarh Excise Act, 1915.

Source reference: para. 1

The Court assessed the bail application by considering the facts and circumstances, the nature and gravity of the allegations, the seized liquor, and the applicant’s criminal antecedents.

Source reference: para. 6
04

Reasoning

The Court considered that the alleged liquor was seized from the applicant’s house and that she had four prior cases under the Excise Act, including two pending cases under Section 34(2).

Source reference: para. 6

Although the applicant had been in custody and the charge-sheet had been filed, the Court treated the repeated antecedents as indicating that she was a habitual offender and concluded that bail was not warranted.

Source reference: para. 3, 6
05

Holding

The Court declined to grant regular bail, finding the applicant’s four prior Excise Act cases—including two pending cases—sufficient to characterize her as a habitual offender.

The bail application was dismissed.

Source reference: para. 7
06

Acts & Sections Cited

1 provisions across 1 statute referred to in this judgment. Each provision opens on LawLens.

Bharatiya Nagarik Suraksha Sanhita, 20231

Chhattisgarh High Court

Original Court PDF

ANITA BANJAREvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · September 30, 2026

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