Regular bail granted due to prolonged custody, non-filing of the charge-sheet, and anticipated trial delay.

The applicant sought regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, in connection with Crime No. 432/2026 registered at Police Station Kotwali, Ambikapur, for alleged offences under Sections 318(4) and 317(4) of the Bharatiya Nyaya Sanhita, 2023.

The prosecution alleged that, after receiving information from the Cyber Cell regarding bank accounts linked to cyber-fraud complaints, the applicant opened bank accounts in his own name and handed their details to co-accused Ayush Sinha @ Deep, who allegedly used them to receive proceeds of cyber fraud.

The applicant was allegedly paid a commission of ₹4,000 per bank account.

The applicant denied the allegations and contended that there was no cogent material connecting him with the offence, that the relevant bank documents were already with the investigating agency, and that further custodial detention was unnecessary.

He also relied upon bail granted to him by the Supreme Court in another crime and bail granted in Crime No. 05/2026, involving the same bank account.

The State opposed bail on the ground that the applicant had two criminal antecedents.

The applicant had remained in judicial custody since 26 June 2026; the Court recorded that the charge-sheet had not yet been filed and that the trial was likely to take considerable time.

Whether the applicant was entitled to regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, in view of the allegations under Sections 318(4) and 317(4) of the Bharatiya Nyaya Sanhita, 2023?

Whether the applicant’s period of custody, the non-filing of the charge-sheet, and the likelihood of delay in conclusion of trial justified release on bail despite the State’s objection based on his criminal antecedents?

The Court applied Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, which empowers the High Court or Court of Session to grant regular bail to a person accused of an offence and in custody.

The alleged substantive offences were Sections 318(4) and 317(4) of the Bharatiya Nyaya Sanhita, 2023.

The governing bail principles required the Court to assess the overall facts and circumstances, the nature and gravity of the allegations, the period of detention, the stage of investigation, and the likely duration of the trial.

The Court also imposed statutory and procedural safeguards concerning the applicant’s appearance, non-seeking of unnecessary adjournments, and consequences for misuse of bail.

The Court considered the case diary and the rival submissions.

Although the prosecution alleged that the applicant knowingly facilitated cyber fraud by providing bank accounts and receiving commissions, the Court ultimately gave weight to the applicant’s continued custody since 26 June 2026, the fact that the charge-sheet had not been filed, and the likelihood that the trial would take considerable time.

The State’s objection based on two criminal antecedents was considered, but it did not outweigh the circumstances supporting release on bail.

The Court therefore exercised its jurisdiction under Section 483 BNSS and balanced the grant of liberty with conditions designed to secure the applicant’s presence and prevent obstruction or misuse of the bail concession.

The High Court directed that Satyam Keshari be released in Crime No. 432/2026 upon furnishing a personal bond with two local sureties in the like amount to the satisfaction of the concerned Court.

The applicant was required, inter alia, not to seek adjournments when witnesses were present, to remain present before the trial court on each date unless represented through counsel where permissible, and to appear personally on the dates fixed for opening of the case, framing of charge, and recording of his statement under Section 351 BNSS.

The Court further directed transmission of the order to the trial court for compliance.