Regular bail granted considering no criminal antecedents, filed chargesheet, prolonged custody, and likely trial delay.

On 14 June 2026, acting on secret information, the Excise Circle, Kota police searched the applicant and allegedly recovered 30 litres of handmade liquor from his bag.

He was arrested the same day, and Crime No. 51/2026 was registered for offences under Sections 34(1)(A), 34(2) and 59(A) of the Chhattisgarh Excise Act.

The applicant filed his first application for regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023.

He claimed false implication, relied on the absence of criminal antecedents, filing of the charge-sheet, the statutory punishment under Section 34(2), and the likely delay in conclusion of the trial.

The State opposed bail, primarily relying on the recovery of 30 litres of handmade liquor.

1. Whether the applicant should be granted regular bail under Section 483 of the BNSS in connection with offences under Sections 34(1)(A), 34(2) and 59(A) of the Chhattisgarh Excise Act.

2. Whether the applicant’s lack of criminal antecedents, filing of the charge-sheet, period of incarceration, quantity of liquor allegedly recovered, and the likelihood of delay in trial justified release on bail.

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

It considered the offences alleged under Sections 34(1)(A), 34(2) and 59(A) of the Chhattisgarh Excise Act, including the punishment prescribed under Section 34(2), which the applicant submitted carries a minimum punishment of one year and a maximum punishment of three years.

The Court applied the settled bail considerations of the nature and gravity of the accusation, the applicant’s criminal antecedents, the stage of the proceedings, the period of custody, and the likelihood of the trial being concluded within a reasonable time.

No judicial precedent was cited.

After examining the case diary and hearing both sides, the Court balanced the allegation concerning recovery of 30 litres of handmade liquor against the mitigating circumstances relied upon by the applicant.

It noted that the applicant had no criminal antecedents, the charge-sheet had already been filed, he had remained in custody since 14 June 2026, and the trial was likely to take time.

Although the State relied on the quantity of liquor recovered, the Court found the cumulative circumstances sufficient to justify regular bail.

The Court directed that Ranjeet Kumar Miri be released on bail upon furnishing a personal bond and two sureties in the like sum to the satisfaction of the trial court.

Bail was subject to conditions requiring him not to seek unnecessary adjournments when witnesses are present, to remain present before the trial court as directed, to comply with proceedings arising from any misuse of bail or non-appearance, and to appear personally at the stages of opening of the case, framing of charge, and recording of his statement under Section 351 of the BNSS.

A certified copy of the order was directed to be sent to the trial court for compliance.