Chhattisgarh High Court

Parity with a co-accused already granted relief justifies the grant of anticipatory bail.

KARAN MANDHAN vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: March 16, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Applicants, comprising Directors and staff of Shubh Commercials (an authorized Isuzu dealership), sought anticipatory bail following the registration of Crime No. 74/2025

Source reference: para. 1-2

The complainant alleged that in December 2022, he purchased an Isuzu Hi-Lander vehicle for Rs. 23,05,521, which was represented by the dealership as a new 2022 model

Source reference: para. 2

It was later discovered that the vehicle was manufactured in 2021 and was allegedly a second-hand demo vehicle

Source reference: para. 2

The Applicants were charged under the Bharatiya Nyaya Sanhita (BNS) for cheating and acting with common intention

Source reference: para. 1
02

Issues

Whether the Applicants are entitled to the grant of anticipatory bail under the Bharatiya Nagarik Suraksha Sanhita (BNSS) based on the principle of parity with a co-accused and the nature of the allegations

Source reference: para. 3-5
03

Law Applied

The Court primarily applied Section 482 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, regarding the High Court's power to grant anticipatory bail

Source reference: para. 1

It further relied on the judicial principle of parity, which mandates similar treatment for similarly situated accused persons, referencing a prior order in M.Cr.C(A) No. 890/2025

Source reference: para. 3-5

The substantive offences considered were Sections 318(4) (Cheating) and 3(5) (Joint Liability/Common Intention) of the Bharatiya Nyaya Sanhita (BNS), 2023

Source reference: para. 1
04

Reasoning

The Court noted that the co-accused, Mohan Mandhan, had already been granted anticipatory bail by a coordinate bench on June 23, 2025

Source reference: para. 3

Upon review, the Court found the present Applicants to be "identically situated" to the protected co-accused

Source reference: para. 5

The Court weighed the fact that the State Counsel did not dispute the parity between the parties

Source reference: para. 4

Additionally, the Court considered the procedural delay, noting that the trial was likely to consume a significant amount of time before conclusion

Source reference: para. 3

Consequently, the Court determined that custodial interrogation was not necessitated under the circumstances

Source reference: para. 5
05

Holding

The High Court allowed the anticipatory bail application

It directed that in the event of arrest, the Applicants be released upon executing a personal bond with one surety each

Source reference: para. 6

The holding was made subject to five specific conditions: (a) no tampering with evidence or witnesses; (b) no prejudice to the trial; (c) mandatory appearance on all trial dates; (d) verification of Aadhaar and identity credentials by the trial court; and (e) a prohibition against committing similar offences in the future

Source reference: para. 6(a)-(e)
Chhattisgarh High Court

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KARAN MANDHANvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · March 16, 2026

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