Facts
The applicant, Mahendra Kumar Katle, was married to the deceased, Anjali Katle.
Source reference: para. 2On June 9, 2025, the deceased committed suicide by hanging at the applicant's residence
Source reference: para. 2Based on an oral report by the deceased’s mother, the police registered an offense under Section 108 of the Bharatiya Nyaya Sanhita (BNS) and arrested the applicant on June 10, 2025
Source reference: para. 2A charge-sheet was filed on August 8, 2025, and the case was committed for trial as Sessions Trial No. 68/2025
Source reference: para. 2The applicant moved for regular bail, arguing that there was no direct evidence of abetment, the trial was delayed due to the non-appearance of prosecution witnesses, and his continued detention since June 2025 was unjustified
Source reference: para. 3Issues
1. Whether the applicant is entitled to regular bail under Section 483 of the Bhartiya Nagarik Suraksha Sanhita (BNSS), 2023, in light of his period of incarceration and the status of the investigation
Source reference: para. 1, 6Law Applied
The court primarily applied Section 483 of the Bhartiya Nagarik Suraksha Sanhita (BNSS), 2023, regarding the High Court’s power to grant regular bail
Source reference: para. 1The substantive offense invoked was Section 108 of the Bharatiya Nyaya Sanhita (BNS), which pertains to the abetment of suicide
Source reference: para. 1Additionally, the court referenced procedural safeguards and consequences for the misuse of bail under Sections 84, 209, 269, and 351 of the BNSS/BNS
Source reference: para. 7Reasoning
The court reasoned that because the charge-sheet had already been filed, the risk of the applicant tampering with evidence or influencing prosecution witnesses was significantly reduced
Source reference: para. 6It noted that the applicant had no prior criminal antecedents and had already been in custody for nearly ten months (since June 10, 2025)
Source reference: para. 6The court further observed that the trial was likely to be prolonged, specifically citing the non-appearance of prosecution witnesses for cross-examination as a factor contributing to the delay
Source reference: para. 3, 6Weighing the nature of the allegations against the applicant’s personal circumstances and the lack of immediate prospect of trial conclusion, the court found it appropriate to exercise its discretion in favor of liberty
Source reference: para. 6Holding
The court allowed the bail application and directed the release of the applicant on bail upon furnishing a personal bond with two local sureties
The holding was conditional upon the applicant not seeking adjournments when witnesses are present, appearing personally on key trial dates (framing of charges, recording of statements), and adhering to procedural mandates under the BNSS to prevent the abuse of the liberty granted
Source reference: para. 7Original Court PDF
MAHENDRA KUMAR KATLEvsSTATE OF CHHATTISGARH
Click to open original judgment
Original judgment, available to read, download and summarize on LawLens.in