Regular bail granted where the chargesheet was filed, trial would be prolonged, and most antecedents ended in acquittal.

The applicant was arrested in connection with Crime No. 102/2026 registered at Police Station Bhanupratappur, District Uttar Bastar Kanker, for offences under Sections 296, 115(2), 351(2), 238, 109 and 309(4) of the Bharatiya Nyaya Sanhita, 2023 (“BNS”).

The prosecution alleged that on 13.05.2026 at approximately 10:00 p.m., the complainant, Bhupendra Sahu, was robbed of his mobile phone and ₹3,000 and assaulted with hands and fists, causing injuries.

The initial report was lodged against unknown persons.

The applicant contended that he was implicated only on the basis of the memorandum of co-accused persons, that the complainant’s injuries were simple, and that no looted article had been recovered from him.

He had been in custody since 15.05.2026; of his three criminal antecedents, he had been acquitted in two cases and one case remained pending.

The charge-sheet had been filed, and the trial was expected to take time.

The State opposed bail primarily on the ground of the applicant’s criminal antecedents.

Whether the applicant was entitled to regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, considering the nature of the allegations, the evidence relied upon, his period of custody, criminal antecedents, and the filing of the charge-sheet.

Whether bail should be granted subject to conditions designed to secure the applicant’s presence and prevent misuse of the liberty of bail.

The Court applied Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (“BNSS”), which empowers the High Court to grant regular bail to a person accused of an offence and impose appropriate conditions.

The Court considered the nature and seriousness of the allegations, the period of incarceration, the status of the investigation, the filing of the charge-sheet, the likely duration of the trial, and the applicant’s criminal antecedents as relevant bail considerations.

The offences alleged were those punishable under Sections 296, 115(2), 351(2), 238, 109 and 309(4) of the BNS.

No judicial precedent was cited or relied upon.

Without expressing any opinion on the merits, the Court balanced the prosecution’s allegations against the circumstances favouring release.

It noted that the applicant had remained in custody since 15.05.2026, the charge-sheet had already been filed, and the trial was likely to take considerable time.

The Court also took into account that two of the applicant’s three criminal antecedent cases had ended in acquittal, leaving only one pending antecedent.

These factors outweighed the State’s objection based solely on the existence of criminal antecedents.

The applicant’s release was nevertheless made conditional upon furnishing a personal bond with two local sureties and complying with detailed attendance and non-adjournment requirements.

Manilal Usendi was directed to be released on bail in Crime No. 102/2026 upon furnishing a personal bond and two local sureties in the like amount to the satisfaction of the concerned trial court.

The conditions required him not to seek adjournments when witnesses were present, to remain present before the trial court as directed, to appear personally on the dates fixed for opening of the case, framing of charge and recording of his statement under Section 351 BNSS, and to comply with the consequences of absence or misuse of bail liberty.

A certified copy of the order was directed to be transmitted to the trial court for compliance.