Regular bail granted on parity where a similarly situated co-accused had already secured bail.

The applicant was arrested in connection with Crime No. 59/2026 registered at City Kotwali Police Station, Raigarh, for offences under Sections 420, 467, 468 and 471 of the Indian Penal Code.

The prosecution alleged that co-accused Narendra and Sonam Sahu had submitted forged mark-sheets while applying online for the post of Gram Dak Sevak in 2023.

Following their arrest, they allegedly named the applicant in their memorandum statements, pursuant to which he was arrested on 13 July 2026.

The charge-sheet had been filed before the Trial Court.

The applicant sought regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, principally relying on parity with co-accused Narendra Kumar Chandra, who had already been granted bail by the High Court in MCRC No. 2436 of 2026 on 28 April 2026.

1. Whether the applicant was entitled to regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, in a prosecution involving Sections 420, 467, 468 and 471 of the IPC.

2. Whether the applicant was entitled to bail on the ground of parity with the identically situated co-accused who had already been granted bail.

3. Whether the filing of the charge-sheet and the applicant’s period of custody justified release on bail, particularly when the trial was likely to take time.

The Court applied Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, governing the High Court’s power to grant regular bail.

The alleged offences were under Sections 420, 467, 468 and 471 of the Indian Penal Code, relating respectively to cheating, forgery of valuable security or specified documents, forgery for the purpose of cheating, and using a forged document as genuine.

The Court also applied the principle of parity, under which an accused similarly situated to a co-accused who has already been granted bail may ordinarily receive similar relief, subject to the facts and circumstances of the individual case.

Relevant considerations included the filing of the charge-sheet, the period of incarceration, and the likelihood of delay in conclusion of the trial.

The Court considered the case diary and noted that the applicant had been in custody since 13 July 2026, the investigation had culminated in the filing of the charge-sheet, and the trial might take considerable time.

The State opposed the application but could not dispute that an identically situated co-accused, Narendra Kumar Chandra, had already been granted bail by the High Court.

Applying the principle of parity, along with the completion of investigation and the anticipated delay in trial, the Court held that continued detention of the applicant was not warranted at that stage.

The Court directed that the applicant, Vinod Kumar Rathour, be released on bail in Crime No. 59/2026 upon furnishing a personal bond with two sureties in the like amount to the satisfaction of the Trial Court.

Bail was granted subject to conditions requiring the applicant not to seek unnecessary adjournments when witnesses were present, to remain present before the Trial Court as directed, to comply with proceedings concerning his absence or non-appearance, and to appear personally on the dates fixed for opening of the case, framing of charge, and recording of his statement under Section 351 of the BNSS.

A certified copy of the order was directed to be sent to the Trial Court for compliance.