Post-charge-sheet detention, absent antecedents or flight and witness-tampering risks, justifies bail.

The three petitioners sought bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, in Khurda Model P.S. Case No. 106 of 2026, corresponding to G.R. Case No. 217 of 2026, pending before the learned SDJM, Khurda.

The prosecution alleged offences under Sections 318(2), 336(2), 340(1), 61(2) and 3(5) of the Bharatiya Nyaya Sanhita, 2023, read with Sections 65 and 72 of the Information Technology Act, 2000.

The allegation was that Sanatana @ Sanatan Barik opened multiple bank accounts in the names of different persons at the inducement of co-accused Prakash Kumar Sahoo for monetary gain, while Lalu @ Diptee Ranjan Jayasingh acted as an intermediary by procuring accounts from local residents for use in financial transactions.

Prakash Kumar Sahoo allegedly received ₹1,66,348, and Lalu @ Diptee Ranjan Jayasingh allegedly received ₹2,39,000 with the assistance of co-accused Ajit Kumar Samantasinghar, whereas the alleged total financial fraud was ₹10,41,02,941.28.

The petitioners had been in custody since 5 April 2026 and 10 July 2026, respectively; a charge-sheet had been submitted, and no criminal antecedents were reported against them.

Whether the petitioners should be released on bail under Section 483 of the BNSS in view of the allegations, the alleged magnitude of the fraud, and the offences invoked.

Whether the petitioners’ period of pre-trial detention, submission of the charge-sheet, absence of criminal antecedents, and lack of material indicating risk of absconding or witness intimidation justified the grant of bail.

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

The alleged offences arose under Sections 318(2), 336(2), 340(1), 61(2) and 3(5) of the BNS, read with Sections 65 and 72 of the Information Technology Act.

It considered the nature and gravity of the accusations, the specific role attributed to each accused, the period of pre-trial detention, filing of the charge-sheet, criminal antecedents, and the likelihood of absconding or influencing witnesses.

The Court also relied on the fundamental principle that an accused is presumed innocent until proven guilty at trial.

Although the alleged financial fraud was substantial, the Court assessed the petitioners’ individual allegations and the overall circumstances rather than determining guilt at the bail stage.

It noted that the petitioners had remained in custody for a significant period, the charge-sheet had already been filed, and no criminal antecedents were reported.

There was also no material suggesting that they would abscond or threaten or influence witnesses if released.

Applying the presumption of innocence and the established bail considerations under Section 483 BNSS, the Court found that continued pre-trial detention was not warranted, while expressly refraining from expressing any opinion on the merits.

Sanatana @ Sanatan Barik, Prakash Ku. Sahoo, and Lalu @ Diptee Ranjan Jayasingh were directed to be released on bail on furnishing bonds of ₹50,000 each with two solvent sureties for the like amount, subject to the satisfaction of the court in seisin of the case and such further conditions as that court deemed appropriate.

The applications were accordingly disposed of, and directions were issued for communication of the order to the concerned court and jail authorities.