Chhattisgarh High Court

Regular Bail Granted in Alleged Abetment of Suicide Case Lacking Direct Evidence and Suicide Note.

NAYANDAS MANIKPURI vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: April 22, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant, a government servant, filed a first bail application under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023.

Source reference: para 1

On 17.11.2025, the deceased, Shesh Narayan Sahu, died after being run over by a train.

Source reference: para 2

Investigation revealed that the applicant allegedly owed the deceased Rs. 4,10,000/- and had threatened him upon demand for repayment. A WhatsApp message from the deceased suggested mental distress due to this conduct.

Source reference: para 2

The applicant was arrested on 01.04.2026 for abetment of suicide, following a 115-day delay in lodging the FIR.

Source reference: para 2, 3

The applicant contended that the deceased was under depression due to financial dealings and that no documentary evidence or suicide note existed.

Source reference: para 3
02

Issues

1. Whether the applicant is entitled to regular bail under Section 483 of the BNSS, 2023, considering the nature of the allegations and the period of incarceration.

Source reference: para 6
03

Law Applied

The court applied Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, governing the grant of regular bail.

Source reference: para 1

The substantive offense was considered under Section 108 of the Bharatiya Nyaya Sanhita (BNS), 2023, which pertains to the abetment of suicide.

Source reference: para 1, 7

The court also referenced procedural compliance for trial attendance and the consequences of defaulting on bail conditions under Sections 269, 84, 209, and 351 of the BNS/BNSS.

Source reference: para 7
04

Reasoning

The Court examined the gravity of the allegations alongside the absence of concrete evidence. It noted that the prosecution failed to produce documentary evidence to substantiate the alleged financial threats and that no formal suicide note was recovered.

Source reference: para 6

The Court took significant note of the fact that the applicant had no previous criminal antecedents and that the charge-sheet had already been filed, indicating that the investigation regarding the applicant was largely complete.

Source reference: para 3, 6

Given that the applicant had been in judicial custody since 01.04.2026 and the trial was expected to take a considerable amount of time, the Court found no justification for continued detention.

Source reference: para 6
05

Holding

The Court allowed the bail application and ordered the release of the applicant on a personal bond with two sureties.

The holding was based on the lack of documentary evidence for harassment and the filing of the charge-sheet. The Court imposed several conditions, including a mandate that the applicant must not seek unnecessary adjournments, must appear personally during key trial stages such as framing of charges, and warned that failure to appear would result in proceedings under Section 209 of the BNS.

Source reference: para 6, 7(i), 7(iv), 7(iii)
Chhattisgarh High Court

Original Court PDF

NAYANDAS MANIKPURIvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · April 22, 2026

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