Chhattisgarh High Court

Regular bail denied for dishonest procurement of funds through false promises of providing government employment.

SANTOSH KUMAR PATEL @ SANTOSH PATEL vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: March 19, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant sought regular bail following his arrest on November 12, 2025, in connection with Crime No. 92/2025.

Source reference: para 1, 3

It is alleged that between 2020 and 2025, the applicant induced the complainant to pay approximately Rs. 72,00,000/- by falsely promising to secure government police jobs for her children.

Source reference: para 2

The complainant reportedly raised this sum through land sales and loans.

Source reference: para 2

When the return of the money was demanded, the applicant allegedly threatened the complainant’s family.

Source reference: para 2

The applicant contended that the amount was exaggerated and that he had only received Rs. 17–18 lakhs.

Source reference: para 3

Following an investigation, a charge-sheet was filed for various offenses under the Bharatiya Nyaya Sanhita (BNS) and the Information Technology (IT) Act.

Source reference: para 2, 4
02

Issues

Whether the applicant is entitled to the grant of regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, considering the nature of the allegations and the conduct of the parties.

Source reference: para 1, 6
03

Law Applied

The Court considered Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, regarding the High Court's power to grant bail.

Source reference: para 1

The substantive charges were brought under Sections 318(2) (Cheating), 319(2) (Cheating by personation), 336(3) (Forgery), 340 (Using forged document), and 238(C) of the Bharatiya Nyaya Sanhita (BNS), alongside Sections 66(C) and 66(D) of the Information Technology Act (punishment for identity theft and personation using computer resources).

Source reference: para 1, 7

The court applied the principle that the nature and gravity of the offense, the material in the case diary, and the conduct of the accused are primary considerations in bail adjudications.

Source reference: para 6
04

Reasoning

The Court evaluated the gravity of the offense, noting the substantial sum of money involved (allegedly Rs. 72,00,000/-) and the deceptive nature of the promise regarding government employment.

Source reference: para 6

Although the applicant’s counsel argued that the amount was inflated and that the applicant had been in custody since November 2025, the Court emphasized the applicant's conduct.

Source reference: para 3, 6

Specifically, the Court observed that the applicant had accepted money to facilitate employment through "illegal modes".

Source reference: para 6

Despite the charge-sheet having been filed, the Court determined that the nature of the fraud and the threats allegedly issued by the applicant outweighed the arguments for release.

Source reference: para 6
05

Holding

The Court held that this was not a fit case for the exercise of discretionary power to grant regular bail.

The bail application of Santosh Kumar Patel was rejected.

Source reference: para 7

The Court granted the trial court liberty to proceed and conclude the trial expeditiously and directed that a copy of the order be sent to the trial court for compliance.

Source reference: para 8, 9
Chhattisgarh High Court

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SANTOSH KUMAR PATEL @ SANTOSH PATELvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · March 19, 2026

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