Regular bail granted post-filing of charge-sheet considering duration of pretrial custody and delayed trial conclusion.

The applicant was arrested in connection with Crime No. 90/2025 following a complaint dated February 6, 2025, regarding a motorcycle theft that occurred on February 3, 2025

Investigation led to the arrest of four individuals, including the 19-year-old applicant, several months later

The prosecution alleged that the applicant was part of a motorcycle theft syndicate, claiming the recovery of 16 motorcycles based on memorandum statements

The applicant contended that no stolen property was recovered from his exclusive possession and that his implication was based solely on coercive memorandum statements

While the applicant claimed no criminal history, the State alleged one previous criminal antecedent

The applicant had been in custody since December 6, 2025

1. Whether the applicant is entitled to the grant of regular bail under Section 483 of the Bhartiya Nagarik Suraksha Sanhita, 2023, considering the completion of the investigation and the duration of his incarceration

The court applied Section 483 of the Bhartiya Nagarik Suraksha Sanhita (BNSS), 2023, which governs the grant of regular bail

The substantive charges were framed under Sections 303(2) (theft), 112(2) (abetment/petty organized crime), and 3(5) (common intention) of the Bharatiya Nyaya Sanhita (BNS)

The court also adhered to the principle that bail may be granted when the investigation is complete (charge-sheet filed), the trial is unlikely to conclude soon, and the accused has undergone significant pre-trial detention

The court evaluated the gravity of the allegations involving an organized theft syndicate against the procedural status of the case

It observed that the investigation had concluded and the charge-sheet had already been submitted to the competent court

Despite the State’s opposition regarding the applicant's criminal antecedent, the court prioritized the fact that the applicant had remained in jail since December 6, 2025, and acknowledged that the conclusion of the trial would be protracted

By balancing the nature of the evidence (largely memorandum-based) with the period of detention, the court determined that continued custody was not warranted

The court ordered his release upon furnishing a personal bond with two local sureties, subject to strict conditions: the applicant must not seek adjournments during witness testimony, must appear personally at key trial stages (framing of charges and Section 351 BNSS statements), and must comply with all procedural requirements to avoid proceedings under Sections 209 or 269 of the BNS