Chhattisgarh High Court
Criminal LawCriminal Procedure and Evidence

Regular bail granted despite one disposed similar antecedent and seizure of 13 litres of liquor.

SATYANARAYAN BHAINA vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: October 01, 20262 MIN READSOURCE JUDGMENT
Regular bail granted despite one disposed similar antecedent and seizure of 13 litres of liquor.. SATYANARAYAN BHAINA vs STATE OF CHHATTISGARH. Chhattisgarh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant was arrested in connection with Crime No. 264/2026, registered at Police Station Nawagarh for an offence under Section 34(2) of the Chhattisgarh Excise Act, 1915.

Source reference: para. 1–4

The prosecution alleged that police seized 13 bulk litres of country-made liquor from his house following information from an informer.

Source reference: para. 1–4

The applicant had one previous criminal antecedent of a similar nature, which had been disposed of.

Source reference: para. 1–4

He had been in custody since 22 August 2026, and sought regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS).

Source reference: para. 1–4
02

Issues

Whether the applicant should be released on regular bail in the circumstances of the case, including the alleged seizure, his previous antecedent, and the expected duration of trial.

Source reference: para. 3–6
03

Law Applied

Section 483 of the BNSS provides the basis for the High Court’s consideration of the application for regular bail.

Source reference: para. 1

The alleged offence was under Section 34(2) of the Chhattisgarh Excise Act, 1915.

Source reference: para. 1

In deciding bail, the Court considered the circumstances of the case, the nature and gravity of the allegations, the applicant’s antecedent, the period of custody, and the likely time for conclusion of trial.

Source reference: para. 6
04

Reasoning

The Court weighed the alleged seizure of 13 litres of country-made liquor and the applicant’s similar antecedent against the fact that the antecedent had been disposed of, the applicant’s custody since 22 August 2026, and the likelihood that trial would take time to conclude.

Source reference: para. 6

On that assessment, it found the applicant entitled to regular bail.

Source reference: para. 6
05

Holding

The Court allowed the bail application.

It directed release upon execution of a personal bond of ₹50,000 with one surety for the like sum, to the satisfaction of the trial Court.

Source reference: para. 7

The applicant must not influence or threaten persons acquainted with the case, must not prejudice a fair and expeditious trial, and must attend each hearing until trial concludes.

Source reference: para. 7

The Court clarified that its observations were confined to the bail application and would not affect the trial Court’s decision on the merits.

Source reference: para. 8
06

Acts & Sections Cited

1 provisions across 1 statute referred to in this judgment. Each provision opens on LawLens.

Bharatiya Nagarik Suraksha Sanhita, 20231

Chhattisgarh High Court

Original Court PDF

SATYANARAYAN BHAINAvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · October 01, 2026

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