Regular bail granted where charge-sheet was filed, custody was prolonged, and the accused had no criminal antecedents.

The applicant was arrested in connection with Crime No. 171/2026 registered at Police Station Koni, Bilaspur, for an offence punishable under Section 310(2) of the Bharatiya Nyaya Sanhita, 2023 (“BNS”).

The prosecution alleged that the complainant, a contractor engaged in roof-centering work, was contacted by co-accused persons who offered to provide labourers.

After receiving an advance of ₹1,000, they called him to Bilaspur and took him to Koni Polytechnic College.

At a deserted location, the accused allegedly threatened the complainant and forcibly took his bag containing ₹45,000, a cheque book, ATM card, passbook and other documents.

The incident allegedly occurred on 14 April 2026, while the FIR was lodged on 17 April 2026.

The applicant’s name was not mentioned in the FIR and he was implicated during investigation.

The applicant had been in judicial custody since 15 May 2026, had no criminal antecedents, and the charge-sheet had already been filed.

The State opposed bail, relying principally on the recovery of ₹1,000 from the applicant.

Whether the applicant should be enlarged on regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, despite the allegation of robbery under Section 310(2) BNS and the recovery of ₹1,000 from him.

Whether the applicant’s prolonged custody, filing of the charge-sheet, absence of criminal antecedents, delay in lodging the FIR, and likelihood of a protracted trial justified the grant of bail.

The Court applied Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (“BNSS”), governing the High Court’s power to grant regular bail, in relation to the offence under Section 310(2) BNS.

The Court considered the established bail principles requiring assessment of the nature and gravity of the accusation, the period of custody, the stage of investigation, the applicant’s criminal antecedents, and the likelihood of the trial being concluded within a reasonable time.

No judicial precedent was cited or relied upon.

The Court considered the prosecution allegations and the State’s objection regarding recovery of ₹1,000, but found the overall circumstances favourable to the applicant.

In particular, the Court took into account that the charge-sheet had been filed, the applicant had remained in custody since 15 May 2026, he had no previous criminal antecedents, and the trial was likely to take considerable time.

The alleged three-day delay in lodging the FIR and the fact that the applicant was not named in the FIR were also circumstances advanced in support of bail.

On a cumulative assessment of these factors, the Court held that continued detention was not necessary at that stage and that the applicant could be released subject to stringent conditions.

The bail was subject to conditions requiring him not to seek unnecessary adjournments when witnesses were present, to remain present before the trial Court on every scheduled date, to comply with proceedings arising from any absence or misuse of bail, and to appear personally at the stages of opening of the case, framing of charge, and recording of his statement under Section 351 BNSS.

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