### Third Regular Bail Granted Upon Discharge of Major Forgery Charges Showing Change in Circumstances

The applicant, Anwar Khan, filed a third bail application under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, regarding Crime No. 1446 of 2024.

He was arrested on November 28, 2025, for allegedly purchasing property from one Pradeep Patel based on a forged mutation order.

While his previous bail applications were dismissed (one withdrawn, one on merits), the applicant sought fresh consideration on the ground that the trial court, on April 18, 2026, discharged him of the more serious offenses under Sections 467 and 468 of the IPC.

The prosecution alleges the applicant participated in a conspiracy involving forged land records.

Whether the discharge of the applicant from offenses under Sections 467 and 468 of the IPC constitutes a material change in circumstances warranting the grant of regular bail.

Whether the applicant, as a purchaser in the transaction with no criminal antecedents, is entitled to bail pending trial.

The court primarily applied Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, which governs the power of the High Court to grant bail.

When investigation is complete and the final report submitted, the necessity for continued incarceration diminishes.

Sections 120-B, 466, and 471 of the IPC carry a maximum sentence of seven years.

Standard bail jurisprudence regarding the "likelihood of tampering with evidence," "criminal antecedents," and "socio-economic status" to evaluate the risk of recidivism or fleeing justice.

The court reasoned that a significant change in circumstances occurred since the rejection of the second bail application, specifically the applicant’s discharge from the graver charges of Sections 467 and 468 IPC.

The court observed that the applicant is a purchaser in the disputed transaction and that the prosecution's case rests largely on documentary evidence (registered sale deeds and mutation records) which are already part of the final report.

Given that the investigation is complete, the applicant has no prior criminal record, and he has already undergone five months of custody, the court found no compelling reason to keep him incarcerated while the trial—which is expected to take time—proceeds.

The court noted that the applicant’s role and complicity would be a matter of evidence during the trial, but at this stage, the contentions of the defense were not "manifestly baseless".

The Court allowed the application and directed that Anwar Khan be released on bail upon furnishing a personal bond of Rs. 25,000/- with one surety of the same amount subject to conditions including regular appearance in court, refraining from committing similar offenses, and non-interference with witnesses or evidence.