Victim compromise is not a determinative factor for bail in serious offences involving habitual offenders.

The applicant filed a First Bail Application under Section 483 of the Bhartiya Nagrik Suraksha Sanhita (BNSS), 2023, seeking regular bail

The prosecution alleged that on December 8, 2025, the complainant and a friend intervened in a market dispute, after which the applicant became aggressive, threatened them with a knife, and inflicted repeated blows upon the complainant

The complainant sustained grievous injuries near his private parts

The applicant was arrested and a button knife was recovered from his residence

The applicant argued that the case was exaggerated, lacked independent witnesses, and that he had completed over four months of incarceration

Notably, the complainant/objector filed a "no objection" application, stating that a voluntary compromise had been reached outside of court

1. Whether the applicant is entitled to regular bail under Section 483 of the BNSS, 2023, considering the compromise between the parties and the period of incarceration?

2. Whether the existence of extensive criminal antecedents and the gravity of the offense outweigh a complainant’s "no objection" in a bail proceeding?

The Court applied Section 483 of the Bhartiya Nagrik Suraksha Sanhita, 2023, regarding the grant of regular bail

the nature and gravity of the offense, the severity of the injury, and the potential for witness intimidation are primary considerations in bail matters

Deepak Yadav v. State of Uttar Pradesh & Another (2022) 8 SCC 559, which mandates that a history of criminal antecedents is a valid ground for the denial or cancellation of bail

The Court balanced the applicant's arguments regarding the compromise and incarceration against the State's concerns regarding public safety and the applicant's history

The Court observed that the "no objection" filed by the complainant cannot be the "sole basis" for granting bail in cases involving serious violence and grievous injuries

It noted that the weapon of offense (a button knife) was recovered from the applicant, prima facie supporting the prosecution’s version

the Court scrutinized the applicant’s criminal record, which included 19 antecedents—only five of which were explained

The Court characterized the applicant as a "habitual offender" who had previously misused the liberty of bail

Applying the ratio from Deepak Yadav, the Court reasoned that the risk of the applicant tampering with evidence or intimidating witnesses was high, given his violent history and the gravity of the specific assault

It held that the serious nature of the injuries, the recovery of the weapon, and the applicant's status as a habitual offender necessitated continued detention to ensure a fair trial

The Court directed the trial court to proceed and conclude the trial expeditiously and ordered a copy of the judgment to be sent for compliance