Regular bail granted on grounds of parity and lack of prior criminal antecedents.

The applicant, Shravan Dhruw, was arrested in connection with Crime No. 327/2025 for allegedly being part of a group of 6–7 persons who impersonated Income Tax officials to conduct a raid at the residence of the complainant, Dilip Rathore, on 17.11.2025

The complaint was filed on 12.12.2025, and the applicant has been in custody since 16.12.2025

A charge-sheet has been filed, and the applicant moved for regular bail primarily on the ground that three co-accused persons (Jitendra Baghel, Sanjay Kumar Ramteke, and Vivek @ Vicky Korsewada) had already been granted bail by the High Court in March 2026

Whether the applicant is entitled to regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, based on the principle of parity and the completion of the investigation?

The Court applied Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, which governs the High Court's power to grant regular bail

The applicant was charged under Sections 204, 319(2), 331(3), 61(2), and 3(5) of the Bharatiya Nyaya Sanhita (BNS), 2023

The Court relied on the "Doctrine of Parity," a judicial principle ensuring that similarly situated accused persons are treated equally in matters of bail unless specific distinguishing factors exist

The Court examined the nature and gravity of the offenses alongside the applicant's period of detention since December 2025

It noted that the investigation was complete and the charge-sheet had been filed, suggesting that the applicant's continued custody was not required for interrogation

Crucially, the Court found that the role of the applicant was identical to that of the co-accused who had already been granted bail in MCRC Nos. 2228/2026, 2353/2026, and 2458/2026

The State could not dispute this identity of roles or the fact that the applicant had no prior criminal record

Applying the principle of parity, the Court determined that withholding bail from the applicant while his co-accused were at liberty would be inconsistent with judicial fairness

The applicant was ordered to be released on a personal bond with two sureties, subject to several conditions: (i) a prohibition against seeking adjournments during witness testimony, (ii) mandatory appearance at all trial dates under Section 269 of the BNS, (iii) threat of proceedings under Section 209 BNS for misuse of liberty, and (iv) mandatory personal presence during framing of charges and recording of statements under Section 351 BNSS