Regular bail granted where charge-sheet filed and no proof found of manipulating revenue records.

The applicant, Virendra Gupta, was arrested in connection with Crime No. 45/2025 for allegedly conspiring with a Patwari to manipulate revenue records. It was alleged that the applicant’s name and those of his family members were fraudulently entered into the Bhuiyan Portal for approximately 29.008 hectares of government and private land

The applicant contended that the entries were clerical errors, noting that he never sought any benefit from the land, the Tahsildar had already passed a rectification order on 26.12.2025, and no incriminating data was recovered from his seized electronic devices

The State opposed bail, citing one previous criminal antecedent

Charge-sheet has been filed, and the applicant has been in custody since 13.12.2025

1. Whether the applicant is entitled to the grant of regular bail under Section 483 of the Bhartiya Nagarik Suraksha Sanhita, 2023, considering the nature of the allegations and the progress of the investigation?

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

The Court considered the standard principles for bail, focusing on the nature and gravity of the accusations, the period of incarceration, the stage of the proceedings (filing of the charge-sheet), and the likelihood of the trial's duration

procedural conditions for bail were governed by Sections 269 (non-appearance), 84 (proclamation for person absconding), and 209 (failure to appear in court) of the BNSS and Bharatiya Nyaya Sanhita (BNS)

The Court balanced the gravity of the alleged revenue record manipulation against the procedural status of the case. It noted that the investigation was complete and the charge-sheet had already been submitted before the Judicial Magistrate First Class, Balrampur, rendering further custodial interrogation unnecessary

The Court took cognizance of the fact that the applicant had been in jail since 13.12.2025 and that a trial conclusion would likely take significant time

despite the State's objection regarding a criminal antecedent, the Court found that the facts and circumstances—specifically the completed investigation and the duration of custody—weighed in favor of the applicant's release

The holding is subject to several conditions: (i) the applicant must not seek adjournments during witness presence; (ii) he must appear on all trial dates; (iii) any violation of bail terms or failure to appear under Section 84 BNSS will trigger proceedings under Section 209 BNS; and (iv) personal appearance is mandatory for the opening of the case, framing of charges, and recording of statements under Section 351 BNSS