Second bail application dismissed for absence of substantial change in circumstances.

The applicant sought regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, in connection with Crime No. 240/2025 registered at Police Station Lalbarra, District Balaghat, for offences under Sections 178 and 179 of the Bharatiya Nyaya Sanhita, 2023.

This was the applicant’s second bail application; his first application, M.Cr.C. No. 58412/2025, had been dismissed on merits on 9 February 2026.

The prosecution alleged that co-accused Pramod Katre deposited approximately ₹70,000 on different occasions, that the applicant paid cash amounts to him, communicated with him through WhatsApp and mobile phone, shared payment screenshots, and received ₹10,000 as commission.

The applicant was arrested principally on the basis of the co-accused’s memorandum statement and remained in judicial custody.

The applicant denied knowledge of any counterfeit currency, relied on his professional relationship with the co-accused as a Feno Bank Distribution Manager, pointed out that no counterfeit currency or related instrument had been recovered from him, and asserted that only three of the prosecution’s twenty-five witnesses had been examined, indicating delay in trial.

The State opposed bail, contending that there was no substantial change in circumstances after dismissal of the earlier application and that the investigation material prima facie established the applicant’s involvement.

1. Whether the applicant demonstrated a substantial change in circumstances warranting reconsideration of his second application for regular bail under Section 483 of the BNSS, 2023.

2. Whether, at the bail stage, the material on record justified the applicant’s release despite his alleged involvement in the offences under Sections 178 and 179 of the BNS, 2023.

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

A successive bail application may be reconsidered where there is a substantial change in circumstances after rejection of the earlier application; absent such change, a second application is not ordinarily maintainable on the same basis.

Sections 178 and 179 of the Bharatiya Nyaya Sanhita, 2023 constituted the offences alleged against the applicant.

At the bail stage, the Court is not required to undertake a detailed examination of the evidence or record a definitive finding on the accused’s guilt or innocence.

The Court considered the prosecution’s allegations, the applicant’s competing submissions regarding lack of recovery and absence of knowledge, the custody period, and the progress of the trial.

However, because the earlier bail application had been dismissed on merits, the decisive consideration was whether circumstances had materially changed thereafter.

The Court accepted the State’s objection that no substantial change had been shown.

It also declined to undertake the applicant’s requested detailed assessment of whether the evidence established knowledge, possession, or participation in the alleged counterfeit-currency offence, observing that such an examination was inappropriate at the bail stage.

Accordingly, the asserted absence of recovery, the applicant’s claimed limited role, and the slow progress of trial did not justify reconsideration of the earlier refusal of bail.

The second application under Section 483 of the BNSS, 2023 was dismissed.