Named accused status alone does not bar bail where investigation is complete and no recovery remains.

An agreement was executed between the Blast Furnace Department of Bhilai Steel Plant and R.D.K. Industries for transportation of flue dust. On 26 May 2026, information was received that vehicles bearing registration Nos. CG-04-QT-8797 and CG-08-AW-1475 were allegedly being used to transport iron scrap illegally along with flue dust. Upon inspection on 27 May 2026, the vehicles were allegedly found carrying iron scrap in an unauthorised manner. An FIR was registered as Crime No. 277/2026 at Police Station Purani Bhilai, District Durg, under Sections 303(2), 317(4), 112, 319(2), 336(3), 338, 343(2), 111, 61(2)(A) and 3(5) of the Bharatiya Nyaya Sanhita, 2023, and Sections 25 and 26(1) of the Chhattisgarh Audyogik Suraksha Adhiniyam, 1990

The applicant, alleged to be the owner of the vehicles, was arrested on 15 June 2026 and remained in judicial custody. He claimed that the vehicles had been rented to contractors under valid agreements and that he had no knowledge of the articles being transported. He also asserted that no incriminating material had been recovered from him, that he had no criminal antecedents, and that similarly situated co-accused had been granted bail

The State opposed bail on the grounds that the applicant was named in the FIR, his role was specifically reflected in the prosecution case, and the vehicles used in the alleged offence stood in his name. The State further contended that his defence regarding rental of the vehicles was a matter for trial

Whether the applicant was entitled to regular bail under Section 483 of the BNSS, 2023, considering the nature of the allegations, his being a named accused, and the material collected during investigation?

Whether continued detention was warranted when the charge-sheet had been filed, no recovery remained to be made from the applicant, he had no criminal antecedents, and he had remained in custody since 15 June 2026?

Whether the applicant could rely on parity with co-accused who had already been granted bail, despite the State’s contention that those persons were not named in the FIR?

The Court applied Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, governing the High Court’s power to grant regular bail.

In exercising this discretion, the Court considered the nature and seriousness of the allegations, the material available in the case diary, the period of custody, completion of investigation and filing of the charge-sheet, the possibility of further recovery, criminal antecedents, and the risk of misuse of liberty

The Court also recognised that a defence concerning the applicant’s lack of knowledge and the alleged rental of the vehicles is ordinarily a matter for trial and need not be conclusively determined at the bail stage

Bail was granted subject to conditions intended to secure the applicant’s presence and prevent obstruction of the trial

The Court acknowledged that the applicant was a named accused and that the vehicles allegedly used in the illegal transportation stood in his name; it also noted that the co-accused relied upon for parity had not been named in the FIR

However, the Court held that this circumstance was not by itself determinative of bail. Against the seriousness of the allegations, the Court weighed the absence of any recovery from the applicant, the fact that no further recovery remained, completion of investigation, filing of the charge-sheet, the applicant’s custody since 15 June 2026, and his absence of criminal antecedents

The applicant’s explanation that the vehicles had been rented out was left open for determination at trial, but continued incarceration was considered unwarranted in the circumstances.

Without expressing an opinion on the merits, the Court therefore found the applicant entitled to regular bail

The Court directed that Sanjay Singh be released on regular bail upon furnishing a personal bond with two local sureties in the like amount to the satisfaction of the trial court

The applicant was required not to seek unnecessary adjournments when witnesses were present, to remain present before the trial court on each date either personally or through counsel, and to appear personally on the dates fixed for opening of the case, framing of charge, and recording of his statement under Section 351 of the BNSS

The order further authorised the trial court to proceed in accordance with law in the event of absence, misuse of bail, or failure to appear pursuant to proclamation proceedings