Chattisgarh High Court
Saumya Chaurasia vs The State Of Chhattisgarh on 28 February, 2026
1
2026:CGHC:10604
AFR
HIGH COURT OF CHHATTISGARH AT BILASPUR
ORDER RESERVED ON 24.02.2026
ORDER DELIVERED ON 28.02.2026
ORDER UPLOADED ON 28.02.2026
MCRC No. 1633 of 2026
1 - Saumya Chaurasia D/o Lt. Shri O.N. Chaurasia Aged About 46
Years R/o A/21, Surya Residency, Junwani Road, Kohka, Bhilai, Durg,
Chhattisgarh (Currently Under Judicial Custody At Central Jail, Raipur
Chhattisgarh)
... Applicant(s)
versus
1 - The State Of Chhattisgarh Through Economic Offences Wing (Eow)/
Anti Corruption Bureau (Acb), Headquarter, Opposite Jai Jawan Petrol
Pump, Telibandha, Raipur, Chhattisgarh 492001
... Respondent(s)
For Applicant (s) : Shri Siddhartha Dave, Sr.Advocate assisted by Shri Harshwardhan Parganiha, Shri Mayank Jain, Shri Anshul Rai, Shri Madhur Jain, Shri Harshit sharma, Shri Arpit Goel and Ms. Alekhya Shastry, Advocates through VC and Ms. Manubha Shankar, Advocates For Respondent/State : Shri Praveen Das, Addl. AG 2 (Hon'ble Shri Justice Arvind Kumar Verma) C A V Order The present application arises out of FIR No. 04 of 2024 dated 17.01.2024 registered by the Economic Offences Wing/Anti-Corruption Bureau, Chhattisgarh, for the alleged offences punishable under Sections 420, 467, 468, 471 and 120-B of the Indian Penal Code and Sections 7 and 12 of the Prevention of Corruption Act, 1988. The prosecution case emanates from a communication received from the Directorate of Enforcement alleging the existence of a purported syndicate engaged in irregularities relating to manufacture and sale of liquor in the State of Chhattisgarh during the period 2019-2023. KEY FACTS IN THE BAIL APPLICATION
2. The prosecution alleges the Applicant's complicity in the offences registered vide FIR No. 04 of 2024, imputing her role in a broader conspiracy evidenced primarily through documentary records compiled over a two-year investigation. Despite her non-inclusion in the initial FIR or primary charge-sheet dated 01.07.2024 (followed by seven supplementary charge sheets), subsequent materials unearthed during probe sufficiently connected her to the crime, warranting her arraignment as an accused. Her arrest on 14.01.2026 via production warrant was imperative post-dismissal of anticipatory bail, as the completed investigation, now reliant on documentary evidence in agency custody, nonetheless necessitated custodial interrogation to 3 confront her with incriminating links, amid concerns of potential evidence tampering or non-cooperation. No overt acts are specified, but the cumulative case, bereft of ocular testimony or pending recoveries from her, underscores her integral involvement, distinguishing her from bailed co-accused and justifying pre-trial detention pending trial. The Non-Applicant initially filed a charge-sheet on 01.07.2024 against certain accused persons while indicating that further investigation was continuing. Thereafter, multiple supplementary charge-sheets dated 27.09.2024, 18.11.2024, 30.06.2025, 07.07.2025, 26.08.2025, 24.11.2025 and 20.12.2025 were filed; yet significantly, the Applicant was never implicated therein. The Applicant was subsequently arrested on 14.01.2026 pursuant to a production warrant issued by the Learned Special Court, despite the fact that the investigation had substantially progressed and the entire evidence was documentary in nature and already within the possession of the investigating agency.
3. Prior to the said arrest, the Applicant had been interrogated by the investigating agency while in judicial custody and had fully cooperated with the investigation. There was never any allegation of non-cooperation during the period when she remained available to the investigating authorities. The chronology of events unmistakably reveals that the Applicant's arrest was effected only after the dismissal of her anticipatory bail application by this Court and immediately after she approached the Supreme Court by way of Special Leave Petition, thereby strongly suggesting that the arrest was neither necessitated by investigation nor supported by any emergent circumstance. 4
4. The Applicant had also challenged the legality of her arrest before the Supreme Court of India in W.P. (Criminal) No. 18 of 2026, wherein the Supreme Court by order dated 09.02.2026 directed that the Applicant's regular bail application be considered expeditiously and preferably within two weeks.
5. The prosecution case, as reflected in the FIR, alleges that certain persons were involved in generating illegal proceeds through manipulation of liquor supply mechanisms and that such proceeds were allegedly distributed among various members of the syndicate. However, the FIR itself does not contain any allegation against the Applicant, nor does it disclose any overt act attributable to her. The entire case rests on documentary evidence already seized by the investigating agency. There are no ocular witnesses and no recoveries are contemplated from the Applicant. The Applicant has been subjected to successive arrests by different agencies on substantially identical material, demonstrating a pattern of prolonged incarceration through successive prosecutions, a circumstance which has been repeatedly deprecated by constitutional courts.
6. The prosecution further alleges the Applicant's complicity in the offences registered vide FIR No. 04/2024 imputing her role in a broader conspiracy evidenced primarily through documentary records compiled over a two-year investigation. Despite her non-inclusion in the initial FIR or primary charge-sheet dated 01.07.2024 (followed by seven supplementary charge sheets), subsequent materials unearthed during 5 probe sufficiently connected her to the crime, warranting her arraignment as an accused.
SUBMISSION ON BEHALF OF THE APPLICANT I. Arrest of the Applicant is Unnecessary and Contrary to Settled Principles of Law
7. Learned Senior Counsel for the applicant submits that the arrest of the Applicant in the present case is wholly unwarranted and unjustified. The Applicant was neither named in the FIR nor implicated during the course of investigation for nearly two years, despite filing of the main charge-sheet and seven supplementary charge-sheets. The belated arrest, therefore, demonstrates absence of any material necessitating custodial detention. The Apex Court has repeatedly held that arrest cannot be made in a routine or mechanical manner and must be justified by necessity. In Arnesh Kumar vs State of Bihar (2014) 8 SCC 273, the Apex Court has held that "Arrest brings humiliation, curtails freedom and casts scars forever. No arrest should be made merely because it is lawful for the police officer to do so."
8. The Court has further held that "Police officers must satisfy themselves that arrest is necessary under the parameters laid down under Section 41 CrPC." Similarly, in Mohd. Zubair vs State (NCT of Delhi) (2023) 16 SCC 764, the Apex Court has observed that "The power of arrest is not unbridled. The investigating agency must justify the need for arrest apart from the existence of power."
9. In the present case, the Applicant was not named in FIR, No 6 recovery was made from the Applicant, no custodial interrogation required, investigation is substantially complete. Thus, the arrest is legally unsustainable.
II. Applicant Not Named in FIR or Charge sheets
10. It is submitted that the Applicant was conspicuously absent from the array of accused in FIR No. 04/2024, wherein no specific role or allegation was ascribed to her even at the threshold of offence registration. Despite the Non-Applicant's submission of the main Charge sheet on 01.07.2024, followed by as many as seven Supplementary Charge sheets, the Applicant has neither been named nor arraigned as an accused in any of these documents. In short, it can be stated that the Applicant is not named in FIR No. 04 of 2024, No role is attributed in FIR, No search conducted, No recovery effected and No incriminating material seized. Despite investigation continuing for nearly two years and filing of eight charge sheets, the Applicant was never arraigned as an accused until her arrest. Such belated arrest itself demonstrates absence of necessity. The Supreme Court in Arnesh Kumar vs State of Bihar (2014) 8 SCC 273 held that "No arrest should be made merely because it is lawful to do so. The existence of power is one thing and the justification for exercise of it is quite another."
Similarly in Mohd. Zubair vs State (NCT of Delhi) (2023) 16 SCC 764, it was held that "The power of arrest is not unbridled and must be justified on the touchstone of necessity." However, no such necessity exists in the present case.
III. Absence of Incriminating Material 7
11. The precipitate arrest of the Applicant, effected only after the filing of multiple Chargesheets--none of which implicate her--manifestly underscores a stark vacuum of incriminating evidence against her. This sequence of events belies any pretence of custodial necessity for investigation, rendering the arrest patently arbitrary and disproportionate. There is a binding Supreme Court Precedent ie. Sanjay Chandra v. CBI (2012) 1 SCC 40, lucidly expounded the cardinal principle governing bail:
"The object of bail is to secure the appearance of the accused at the trial... Detention in custody pending completion of trial could be a cause of great hardship."
The Court further cautioned: "The nature and gravity of the charge is not the only test... The Court has to consider whether continued detention isnecessary to serve the ends of justice. Thus, continued incarceration is unjustified where risks are neutralized." IV. Argument for Immediate Release
12. In the instant case, with investigation demonstrably complete (as evidenced by successive Chargesheets omitting the Applicant), prolonged detention offends Article 21 safeguards and contravenes the Sanjay Chandra ratio. Parity demands bail because other co-accused (similarly placed) have been granted liberty, ensuring equal treatment under law per Supreme Court precedents like State of Rajasthan v. Balchand (1977) and Sanjay Chandra v. CBI (2012). Denying bail solely to the Applicant creates invidious discrimination absent distinguishing factors.
V. Successive Arrests Amount To Evergreening Of Custody 8
13. It is submitted that the Applicant stands subjected to a pernicious cycle of successive arrests orchestrated by multiple agencies, predicated on materially indistinguishable allegations, inexorably culminating in protracted incarceration. This insidious practice derisively termed "evergreening of custody"--has been unequivocally deprecated by Constitutional Courts as a subterfuge to circumvent bail entitlements and convert pre-trial detention into de facto punishment. Evergreening Deprecates Constitutional Safeguards.
14. The Supreme Court, in Union of India v. K.A. Najeeb (2021) 3 SCC 713, sternly cautioned:
Courts must ensure that the proceduralmechanism does not become a tool of punishment prior to adjudication of guilt."
This exposition resonates acutely in the instant matrix, where the Applicant's arrest herein--succeeding prior custodial episodes on analogous predicates--manifestly exemplifies evergreening. Such multiplicity neither unearths fresh evidence nor advances investigation but perpetuates custody through artifice, offending guarantee of Article 21 against arbitrary detention.
VI. Imperative for Immediate Relief
15. It is submitted that Permitting continued incarceration under these circumstances would irretrievably erode the sacrosanct presumption of innocence, reducing the judicial process to an instrument of vindictiveness. Parity with co-accused at liberty, coupled with neutralized risks via conditions, mandates bail to forestall this 9 constitutional aberration.
VII. Absence of Flight Risk or Tampering Possibility
16. It is submitted that the Applicant embodies the archetype of a law-abiding citizen with unassailable societal moorings: a permanent resident deeply entrenched in the community, who has consistently honoured judicial summons and extended unstinted cooperation to the investigating agency. Critically, no allegation of witness intimidation mars the record. The Supreme Court in Sanjay Chandra v. CBI (2012) 1 SCC 40 has categorically mandated that :
"If there is no possibility of the accused fleeing from justice or tampering with evidence, bail should normally be granted."
The Applicant incontestably satisfies the hallowed triple test--no flight risk, no tampering potential, and no scope for influencing witnesses--warranting unconditional liberty.
VIII. Bail Not Punitive Measure
17. The Applicant has endured protracted incarceration, whilst the trial's protracted denouement looms indefinitely. Pre-trial detention cannot metamorphose into punishment by proxy. The Supreme Court in Gudikanti Narasimhulu v. Public Prosecutor (1978) 1 SCC 240 pithily has observed:
"The issue of bail is one of liberty, justice, the exigencies of public safety and the fair incidence of the burden upon the public treasury."
Article 21 is a sacrosanct mantle of personal liberty which 10 peremptorily mandates bail, foreclosing any calculus of retribution absent conviction.
IX. Parity with Co-Accused
18. It is further submitted that several co-accused persons similarly situated to the Applicant have already been granted bail by competent courts including the Supreme Court. In particular, co-accused Trilok Singh Dhillon was granted bail by the Supreme Court vide order dated 27.11.2024 passed in SLP (Crl.) No. 14697/2024 and co-accused Anurag Dwivedi was granted bail by the Supreme Court vide order dated 07.03.2025 passed in SLP (Crl.) No. 18386/2024. Interim protection was also granted to several excise officers by the Supreme Court vide order dated 29.08.2025 in SLP (Crl.) No. 12801/2025 and connected matters, which was subsequently confirmed vide order dated 12.11.2025. Further, one of the co-accused excise officers was granted anticipatory bail by this Court vide order dated 14.11.2025 passed in M.Cr.C.(A) No. 1343/2025. The Applicant, therefore, stands on a better footing and is entitled to bail on the ground of parity. X. Applicant Stands on Better Footing Than Co-Accused
19. It is submitted that the Applicant occupies an unassailably superior position vis-à-vis co-accused already enlarged on bail, rendering denial of parity not merely inequitable but manifestly perverse. It is further submitted that several co-accused, identically situated in the array of allegations, have been enlarged on bail by coordinate Benches and even the Supreme Court itself. Denying the Applicant--against whom no distinguishing culpability attaches--the benefit of parity would perpetuate invidious discrimination, offending 11 Article 14 equal protection mandate. The Supreme Court in Ramesh Bhavan Rathod v. Vishanbhai Hirabhai Makwana (2021) 6 SCC 230 authoritatively proclaimed:
"Parity is an important consideration while deciding bail applications, though not an absolute rule."
Equitable consistency imperatively demands the Applicant's release on par with her co-accused.
X. Continued Custody Serves No Purpose
20. With investigation substantially concluded, evidence predominantly documentary in nature, no recoveries outstanding, and the Applicant's unwavering cooperation, custodial exigency stands wholly extinguished. Prolonged incarceration thus extracts a disproportionate toll without advancing justice. The Supreme Court in Satender Kumar Antil v. CBI (2022) 10 SCC 51 directed Courts to:
"Lean in favour of liberty where custodial necessity is absent, rejecting mechanical detention."
This exposition compels bail, as custody herein neither sub- serves investigation nor safeguards public interest. XI. Distinguishing Factors in Applicant's Favour
21. The applicant is not named in FIR No. 04/2024 or any Charge sheet, including the main Charge sheet (01.07.2024) and seven Supplementary Charge sheets. No overt act or specific role attributed at any stage. No recovery effected from her possession. No search 12 conducted at her premises. No incriminating material seized or recovered. Arrest effected nearly two years post-FIR, post-substantial investigation completion. Entire evidence is purely documentary, admitting no custodial necessity.
XII. Contrast with Co-Accused Granted Bail
22. Conversely, several co-accused--who were named in the FIR, arraigned in Charge sheets and allegedly linked to overt acts have nonetheless been granted bail by coordinate Benches and the Hon'ble Supreme Court.
XIII. Imperative for Bail
23. The Applicant's pristine position, bereft of even prima facie complicity, fortifies her claim beyond that of the co-accused. Any refusal of bail would constitute arbitrariness offending Article 14, compelling immediate release on terms securing appearance and trial integrity.
24. It is submitted that the parity in the present case is with orders passed by the Supreme Court itself, which carry binding precedential value and persuasive force. Once the Supreme Court has considered the prosecution case and granted bail to co-accused, similarly placed accused ordinarily deserve similar treatment. The Supreme Court in Nanha vs State of U.P. (1993 Supp (1) SCC 309) held that "where co- accused has been granted bail, another accused on similar footing should ordinarily be granted bail."
25. It is submitted that the Applicant cannot be singled out for continued incarceration when:
13
* Multiple accused granted bail * Supreme Court granted bail * Charge sheets filed * Investigation progressed * Evidence documentary Selective incarceration would amount to punitive detention.
The Supreme Court in Sanjay Chandra vs CBI (2012) 1 SCC 40 has held that " Detention pending trial cannot be punitive."
26. Learned counsel for the applicant submits that in light of the bail granted to several co-accused including by the Supreme Court, the absence of any specific role attributed to the Applicant, the documentary nature of evidence, the absence of recoveries and the fact that the Applicant stands on a substantially better footing than the co- accused already enlarged on bail, it is respectfully submitted that the Applicant is entitled to bail on the ground of parity alone. Denial of bail in such circumstances would amount to unjustified discrimination and arbitrary deprivation of personal liberty, contrary to the settled principles governing grant of bail.
XIV. Successive Arrests Amount to Evergreening of Custody
27. It is submitted that the Applicant has been subjected to successive arrests by different investigating agencies on substantially identical material, resulting in prolonged and continuous incarceration without trial. The Applicant has already been arrested multiple times in different proceedings arising out of the same alleged transactions, which clearly demonstrates a deliberate attempt to evergreen the 14 custody of the Applicant. The present arrest in FIR No. 04 of 2024 is only a continuation of the same pattern, particularly when the alleged material relied upon by the prosecution consists primarily of purported WhatsApp communications of the year 2019-2020, which were already within the knowledge and possession of the investigating agencies for several years.
28. The Supreme Court has recently deprecated the practice of repeated arrests in Binay Kumar Singh vs State of Jharkhand, Criminal Appeal No. 815 of 2026, judgment dated 10.02.2026 and granted bail after observing that successive arrests cannot be permitted to become a mechanism for indefinite incarceration. The Applicant stands on an identical footing and is therefore entitled to bail on this ground alone.
XV. Entire Evidence is Documentary - No Custodial Interrogation Required
29. It is further submitted that the investigation is substantially complete qua the Applicant and the entire evidence is documentary in nature. No further recovery is contemplated and No custodial interrogation is required. The Supreme Court in P. Chidambaram vs Directorate of Enforcement (2020) 13 SCC 337 held that "When the investigation is substantially complete and the evidence is documentary in nature, continued custody may not be necessary." The present case squarely falls within the said principle.
XVI. Selective Arrests Demonstrate Arbitrary Investigation 15
30. It is next submitted that the investigation in the present case is marked by pick and choose arrests, which raises serious concerns regarding procedural fairness. Several categories of persons allegedly connected with the case, including cash aggregators and distillery owners, have not been arrested, whereas the Applicant has been singled out for custodial detention. The Delhi High Court in Vipin Yadav vs Directorate of Enforcement, 2025 SCC OnLine Del 6237 has held that "Pick and choose arrests by the investigating agency is a relevant factor while considering bail." The present case is a classic example of such selective action.
XVII. Further Investigation Conducted Without Judicial Permission
31. It is submitted that successive supplementary charge-sheets have been filed without obtaining the requisite judicial permission. The Supreme Court has consistently held in Vinay Tyagi v. Irshad Ali, (2013) 5 SCC 762; Vinubhai Haribhai Malaviya v. State of Gujarat, (2019) 17 SCC 1; and Robert Laltchungnunga Chongthu v. State of Bihar, 2025 SCC OnLine SC 251, that further investigation must be conducted strictly in accordance with law and remains subject to judicial scrutiny for quashing proceedings due to unexplained delays and procedural lapses.
XVIII. Delay in Trial - Violation of Article 21
32. It is submitted that the trial in the instant case remains nowhere near commencement, with charges yet to be framed despite the prosecution's staggering case load--52 accused, over 1,000 witnesses, thousands of documents, and multiple charge-sheets. Further 16 prolonged incarceration under these circumstances is inevitable if bail is denied, constituting a gross violation of Article 21. The Supreme Court in Union of India v. K.A. Najeeb, (2021) 3 SCC 713 has categorically held that "Where there is little possibility of trial being completed within a reasonable time, continued detention would be violative of Article 21.
33. The petitioner's continued detention, with trial completion nowhere in sight, offends the constitutional guarantee under Article 21 and mandates grant of bail. This formulation strengthens bail petitions under Sections 437/439 CrPC by directly linking case-specific delays to Najeeb's ratio, enhancing persuasive impact.
XIX. Supreme Court Mandate
34. It is submitted that the Supreme Court, in W.P. (Criminal) No. 18 of 2026, vide its order dated 09.02.2026, has issued a specific and binding direction to this Court. The Apex Court has mandated that previous bail orders granted to the Applicant as well as to other co- accused shall be duly considered while adjudicating the present application. The Supreme Court observed with unmistakable clarity:
"The High Court is requested to take up both matters on a priority basis and make an endeavor to decide the same at the earliest, but not later than two weeks. The High Court will also keep in mind the various orders passed by this Court granting bail to the Petitioner and other co-accused."
This directive underscores the doctrine of parity, rendering prior bail grants to similarly situated co-accused a compelling and binding consideration. Denial of bail to the Applicant alone would constitute an 17 arbitrary differentiation, offending Article 14 and undermining the Supreme Court's explicit instructions.
XX. Exemplary Conduct: No Misuse of Prior Liberty
35. It is further submitted that the Applicant has been granted bail on multiple occasions, including by the Supreme Court itself, and has inviolably adhered to all conditions imposed thereof. Not once has the Applicant misused the liberty granted, thereby establishing an unblemished track record of compliance. This impeccable conduct unequivocally demonstrates that the Applicant Poses no flight risk whatsoever and shall remain present throughout the trial; Shall extend full cooperation to the investigative and trial processes; Will scrupulously abide by any conditions that this Court may deem fit to impose. Such conduct, tested across repeated grants of liberty, is the gold standard for bail jurisprudence and tilts the balance decisively in favour of release.
36. It is submitted that the prosecution case is conspicuously bereft of foundational evidentiary pillars, disclosing no sustainable prima facie case case the applicant. The alleged case rests on the shakiest foundations namely,
i) Complete absence of recoveries attributable to or linking the applicant.
ii) No independent witnesses or corroborative material;
iii) Sole reliance on interested statements under Section 161 CrPC, inherently unreliable absent corroboration;
iv) Want of any material corroboration to elevate these statements to 18 probative value;
v) Statements of co-accused, which carry severely limited evidentiary worth.
The Supreme Court in Haricharan Kurmi v. State of Bihar, AIR 1964 SC 1184, authoritatively held that "A confession of a co-accused is not substantive evidence. It can only be pressed into service for lending assurance to other evidence."
37. Reinforcing this principle, in Subramanya v. State of Karnataka, (2023) 11 SCC 255, the Apex Court has reiterated that "Conviction cannot be based solely on the statements of co-accused without independent corroboration. Such evidence, at best, is of a very weak nature." In light of these binding precedents, the prosecution's case against the Applicant collapses at the threshold, rendering continued detention manifestly unjust.
38. In cumulative consideration of the successive arrests sans incriminating recoveries, the purely documentary character of evidence, the belated and patently unnecessary apprehension following protracted investigation, parity with the large cohort of co-accused already enlarged on bail, the binding directives of the Supreme Court mandating consideration thereof and the inevitable protracted delay in trial commencement with charges yet to be framed, it is submitted that the continued incarceration of the Applicant constitutes a grave miscarriage of justice. Such prolonged deprivation of liberty, amidst a prosecution case bereft of substantive evidence and reliant on uncorroborated statements of co-accused, is manifestly arbitrary and 19 violative of the sacrosanct guarantees enshrined under Articles 14 (equality before law) and 21 (right to life and personal liberty) of the Constitution of India. The Applicant has thus established an overwhelmingly compelling case warranting the grant of regular bail forthwith.
SUBMISSIONS ON BEHALF OF THE RESPONDENT/STATE
39. The Non-Applicant/State submits its objections to the grant of regular bail to the Applicant in connection with Crime No. 04/2024 of EOW/ACB, Raipur, registered for offences punishable under Sections 420, 467, 468, 471 and 120-B IPC read with Sections 7 and 12 of the Prevention of Corruption Act, 1988. It is submitted that the instant case unveils a meticulously orchestrated and deeply entrenched liquor scam of staggering proportions, entailing the systematic generation and proliferation of criminal proceeds aggregating to thousands of crores of rupees. The gravity of these economic offences, striking at the nation's fiscal integrity, demands the most stringent judicial vigil to prevent miscarriage of justice.
I. Gravity And Magnitude Of The Offence
40. The investigation has revealed the existence of a structured syndicate comprising public servants, private individuals and intermediaries, who misused official machinery for generation and distribution of illegal proceeds. It is submitted that the Applicant, at the relevant time, by virtue of her exalted position as Deputy Secretary in the Chief Minister's Office, commanded exceptional influence and authority, wielding the same to orchestrate and facilitate the nefarious 20 operations of the syndicate implicated in this colossal liquor scam. The Hon'ble Supreme Court in Y.S. Jagan Mohan Reddy v. CBI, (2013) 7 SCC 439, has authoritatively delineated the distinct jurisprudence governing economic offences, holding "Economic offences constitute a class apart and need to be visited with a different approach in the matter of bail."
The Apex Court further elaborated with perspicuous clarity:
"The magnitude of economic offences and their deleterious impact upon the civilized society must be duly reckoned while considering bail applications. Public interest ordinarily outweighs individual interest in such cases."
41. The instant matter falls squarely within this doctrinal matrix. The Applicant's strategic perch enabled the systematic siphoning and laundering of criminal proceeds running into thousands of crores, imperilling public revenue and eroding institutional integrity at the highest echelons of governance. Her continued incarceration is thus imperative to unearth the full ramification of the conspiracy and forestall any potential tampering or influence peddling.
II. Active Role of the Applicant Established
42. It is submitted that the investigation has unerringly uncovered the Applicant's active and conscious participation in the criminal conspiracy, placing her at the nerve centre of the syndicate's operations. Statements of material witnesses, meticulously recorded under Section 164 CrPC/Section 183 BNSS, irrefutably establish her culpability, including Nikhil Chandrakar (dt. 12.01.2026) Pannalal Loutra (dt. 21 03.02.2026), Garima Sharma (dt. 24.01.2026). These unimpeachable testimonies cogently demonstrate that the Applicant Operated in illegal association with prime accused Anwar Dhebar, exploiting her official position; Distributed syndicate proceeds, facilitating money trails integral to the scam; Issued explicit instructions to subordinates and associates in furtherance of the conspiracy; Coordinated syndicate activities across multiple operational facets; Procured and utilized dedicated SIM cards for clandestine communications; Controlled the entire communication network, ensuring operational secrecy and command. Far from being peripheral, these disclosures position the Applicant as the strategic lynchpin of the conspiracy, whose influence permeated every layer of the illegal apparatus. Such material, when subjected to trial, shall conclusively expose the full dimensions of her complicity, rendering bail at this juncture not merely improvident but antithetical to the ends of justice.
III. Incriminating Digital Evidence Unearthed
43. It is respectfully submitted that the investigation has yielded a treasure trove of incriminating digital evidence, meticulously retrieved and preserved, which inexorably links the Applicant to the heart of the criminal conspiracy. This includes the WhatsApp chats and encrypted communications capturing real-time syndicate deliberations; Mobile call data records evidencing frequent contact with key co-accused; SIM cards procured under false identities, deployed exclusively for covert operations; Draft posting orders manipulated to favour syndicate interests; Official documents illicitly exchanged with co-accused, 22 betraying abuse of public office. The WhatsApp conversations, in particular, lay bare the Applicant's operational coordination with prime accused Anwar Dhebar and Anil Tuteja, pertaining to:Strategic posting of pliable officers to facilitate the scam's unchecked proliferation; Distribution protocols for illegal funds, siphoned from public exchequer; Critical operational decisions sustaining the syndicate's architecture. This digital footprint constitutes prima facie proof of the Applicant's nexus with the conspiracy, rendering her release fraught with the peril of data obfuscation or device sanitization.
IV. Investigation at Crucial Juncture
44. It is further submitted that the investigation remains at a highly sensitive and ongoing stage, with critical investigative facets yet to be concluded. Electronic devices seized from the Applicant's custody and residence are undergoing specialized forensic examination by expert agencies, poised to unravel deeper layers of digital complicity. Further material--encompassing financial trails, additional device extractions, and syndicate ledgers--is anticipated to emerge, completing the unbroken chain of conspiracy. Premature enlargement on bail at this juncture would grievously prejudice the investigative process, potentially frustrating the ends of justice.
The Hon'ble Supreme Court in State v. Amit Kumar, (2017) 13 SCC 751, cautioned with characteristic foresight:
"Where investigation is at a crucial stage, grant of bail may hamper effective investigation and the possibility of the accused influencing witnesses or tampering with evidence cannot be ruled out."23
V. Grave Risk of Witness Intimidation and Evidence Tampering
45. It is submitted that the Applicant, by virtue of her former position as Deputy Secretary in the Chief Minister's Office, continues to wield formidable administrative and political influence, capable of being marshalled to subvert justice. Material witnesses encompass a vulnerable spectrum, including:Senior government officials under her prior command; Private intermediaries integral to money laundering operations; Syndicate employees possessing operational knowledge. Her release would engender a real and imminent danger of:Witness intimidation, through overt or veiled threats leveraging official clout; Evidence tampering, including destruction or fabrication of digital records; Obstruction of forensic analysis via influence over seized devices or custodians. The Supreme Court in Neeru Yadav v. State of U.P., (2016) 15 SCC 422, laid down the sacrosanct principle:
"While granting bail, the Court must consider the likelihood of the accused influencing witnesses or otherwise prejudicing the trial... Persons accused of serious offences, who enjoy positions of power, pose heightened risks."
In the matrix of this case--marked by economic offences of colossal magnitude, the Applicant's centrality, and ongoing probe--bail would imperil the judicial process itself.
VI. Applicant Disentitled to Parity with Co-Accused
46. It is submitted that the Applicant cannot legitimately claim parity with co-accused who have been enlarged on bail. The doctrine of parity 24 is not a mechanical formula to be invoked unthinkingly; rather, it is a nuanced principle contingent upon comparable role, culpability, and circumstances--none of which obtain here. The Applicant occupies a distinctly different and elevated footing, as indubitably borne out by the investigative materials:Occupied the highest administrative position amongst implicated public servants; Served as Deputy Secretary in the Chief Minister's Office, wielding unparalleled authority; Managed the syndicate's day-to-day functioning, acting as its operational backbone; Coordinated complex operational facets spanning multiple jurisdictions; Distributed illegal funds, thereby greasing the wheels of the colossal money laundering apparatus. The Supreme Court in Neeru Yadav v. State of U.P., (2016) 15 SCC 422, authoritatively clarified:
"Parity cannot be claimed where the role attributed to the accused is different and more serious than that of the co-accused who have been granted bail."
Thus shorn of parity, the Applicant's claim collapses, her role emerging as singularly pernicious and demanding continued custody. VII. Criminal Antecedents and Heightened Culpability
47. Compounding her distinct role, the Applicant has thereby established criminal antecedents through her demonstrated complicity in economic offences of unprecedented scale. Such antecedents are not peripheral but a statutory and precedential lodestar in bail adjudication. The Supreme Court in Neeru Yadav v. State of U.P., (2016) 15 SCC 422, unequivocally held:
"Criminal antecedents of the accused are a relevant factor while deciding bail 25 applications. Courts must guard against enlarging those with established patterns of criminality."
48. The Applicant's orchestration of this liquor scam--siphoning thousands of crores--constitutes precisely the species of recidivist economic criminality that militates decisively against bail. VIII. Abuse of Administrative Influence and Public Trust
49. It is submitted that the Applicant exploited her highly sensitive position as Deputy Secretary in the Chief Minister's Office to perpetrate systemic depredations upon public revenue. Her official remit encompassed Administrative control over critical levers of State machinery; Strategic posting of pliable officers to shield and advance syndicate interests; Formulation and manipulation of policy to camouflage illicit operations.The investigation has conclusively revealed the misuse of official machinery for private illegal gain, transforming public office into a personal fiefdom for criminal aggrandizement. This constitutes nothing short of a grievous breach of public trust, eroding the foundational compact between the State and its citizenry. The Supreme Court in Y.S. Jagan Mohan Reddy v. CBI, (2013) 7 SCC 439, sounded a clarion call:
"Economic offences involving public servants must be viewed seriously, as they not only cause monetary loss but also shake the conscience of the society and the collective conscience of the Court."
In this vessel of public betrayal and economic sabotage, the Applicant's release would signal judicial abdication, emboldening future 26 malfeasance.
IX. Seriousness of Offence Trumps Custody Duration
50. It is submitted that the Applicant has been in custody only since 14.01.2026--a patently brief interlude when juxtaposed against the cataclysmic magnitude of the economic offences alleged. The Supreme Court has consistently admonished that the gravity and heinousness of the offence constitute an overriding consideration, dwarfing the temporal aspect of incarceration. In Y.S. Jagan Mohan Reddy v. CBI, (2013) 7 SCC 439, the Apex Court held:
"Serious economic offences require a different approach in the matter of bail. The period of custody alone cannot be the sole criterion."
X. Strong Prima Facie Case Indisputably Established
51. The investigation has amassed an impregnable edifice of evidence establishing a robust prima facie case against the Applicant, including WhatsApp chats chronicling conspiratorial coordination;Covert SIM cards under false identities;Statements of material witnesses under Sections 164 CrPC/183 BNSS; Voluminous digital footprints from seized devices;Irrefutable linkage in BS Diaries (Beat Sheets/Station Diaries);Financial trails tracing illicit siphoning of crores. This evidentiary matrix renders the case against the Applicant unassailable at the bail stage. The Supreme Court in State of Bihar v. Amit Kumar, (2017) 13 SCC 751, cautioned:
"Where a strong prima facie case exists against the accused, bail should not be granted as it would undermine the prosecution's case."27
XI. Applicant Fails the Triple Test
52. The Applicant flouts every prong of the sacrosanoid triple test for bail:Flight Risk: Her powerful position as ex-Deputy Secretary CMO equips her with resources and networks for evasion. Tampering Risk: Digital evidence from her devices remains under forensic scrutiny; release imperils integrity.
Obstruction to Investigation: Probe is nascent and multi-faceted; enlargement would paralyze further disclosures. XII. Binding Precedent of Rejected Anticipatory Bail
53. It is submitted that this Court, vide order dated 13.01.2026, rejected the Applicant's anticipatory bail application, recording categorical findings on:The alarming magnitude of the liquor scam;The Applicant's pivotal and managerial role therein. These findings, rooted in the selfsame material, retain undiminished vitality and bind the present adjudication.
XIII. Distinct Jurisprudence for Economic Offences
54. Economic offences of this stripe demand a rigorous and circumspect approach. The Supreme Court in P. Chidambaram v. Directorate of Enforcement, (2020) 13 SCC 337, proclaimed:
"Economic offences are grave offences and affect the economy of the country as a whole. They cannot be treated at par with other offences."
Echoing this, Y.S. Jagan Mohan Reddy v. CBI, (2013) 7 SCC 28 439, affirmed:
"Economic offences stand on a different footing inasmuch as they affect the economic life of the country."
The Applicant's release would thus subvert this specialized jurisprudence tailored to safeguard the national exchequer.
55. Lastly, it is submitted that in light of the grave nature of the offence, the unassailable prima facie evidence against the Applicant, his active and pivotal role in the conspiracy, the irrefutable digital footprints corroborating his complicity, the nascent stage of the ongoing investigation, the manifest risk of witness tampering and evidence manipulation, his notorious criminal antecedents, and his distinctly culpable role vis-à-vis the co-accused--coupled with the brevity of his custody thus far--the Applicant is wholly undeserving of the extraordinary discretionary balm of bail. The instant matter unveils a colossal edifice of corruption, orchestrated through systematic misuse of public office and methodical criminal syndicate operations. Liberating the Applicant at this critical juncture would not merely thwart the investigative process but would inflict irreparable prejudice upon the sacrosanct administration of justice. The instant bail application therefore be graciously rejected.
FINDINGS AND CONCLUSION
56. I have heard learned Senior Counsel for the Applicant and the learned Additional Advocate General for the State at considerable length. Perused the case diary, written submissions and the documents 29 annexed to the record. The instant application under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, seeks regular bail in connection with Crime No. 04/2024 of EOW/ACB, Raipur, registered for offences punishable under Sections 420, 467, 468, 471, and 120-B of the Indian Penal Code, 1860, read with Sections 7 and 12 of the Prevention of Corruption Act, 1988 (as amended).
Nature of Allegations
57. The prosecution case relates to alleged irregularities in the liquor trade in the State of Chhattisgarh during the period 2019-2023 and the alleged existence of a syndicate engaged in illegal collection and distribution of funds.
58. The State has opposed the application contending that the Applicant, while working as Deputy Secretary in the Chief Minister's Office, played an active role in the alleged syndicate and that incriminating material in the form of witness statements, WhatsApp communications and digital evidence has been collected during investigation.
59. It is further contended by the State that investigation is still in progress and electronic devices are under forensic examination and therefore release of the Applicant at this stage may adversely affect investigation. The State has also contended that the Applicant is involved in other criminal cases and therefore she is not entitled to parity with co-accused.
The record unmistakably discloses that a substantial cohort of co- accused, similarly circumstanced in the conspiracy, have secured 30 liberatory relief from bail through orders of competent jurisdictions, including the august forum of the Supreme Court. Pre-eminently, bail stands granted to Trilok Singh Dhillon (order dt. 27.11.2024); Arun Pathi Tripathi (order dt. 07.03.2025);Anurag Dwivedi (order dt. 07.03.2025);Deepak Duary (order dt. 07.03.2025); Dilip Pandey (order dt. 07.03.2025); Arvind Singh (order dt. 19.05.2025); Amit Singh (Order dated 19.05.2025); Vivek Kumar Goswami and others (order dt. 12.11.2025); Sunil Dutt (Order dated 12.03.2025); Abhishek Singh (Order dt. 11.11.2025); Manish Mishra (Order dt. 11.11.2025); Vijay Bhatia (Order dt. 25.09.2025); Deolal Vaidya (Anticipatory Bai order dt. 14.11.2025); Sanjay Kumar Mishra (Order dt. 23.09.2025); Mukesh Manchanda (Order dt. 13.01.2026); Atul Singh (Order dt. 13.01.2026); Chaitanya Baghel (Order dt. 02.01.2026) and Kawasi Lakhma (order dt. 03.02.2026); whose emancipatory orders adorn the record. This formidable array of precedents, emanating from superior judicial scrutiny, constitutes a material circumstance militating irresistibly for parity. Judicial consistency is an inviolable tenet of bail adjudication which frowns upon arbitrary schism, rendering denial here manifestly discriminatory absent compelling differentiation.
Consideration of Material on Record
60. Having considered the rival submissions and material available on record, certain undisputed circumstances emerge. Firstly, the Applicant was not named in the FIR, nor was any specific role attributed to her at the stage of registration of the crime. 31 Secondly, despite prolonged investigation extending over nearly two years and filing of the main charge-sheet as well as several supplementary charge-sheets, the Applicant was not arrayed as an accused, which is a circumstance of considerable significance. Thirdly, the Applicant came to be arrested only on 14.01.2026 through a production warrant, at a stage when substantial investigation had already been carried out.
Fourthly, it is not disputed that the prosecution case is largely based on documentary and electronic evidence, which is already in possession of the investigating agency. No recovery is stated to be pending from the Applicant.
Necessity (or Otherwise) of Custodial Detention
61. One of the lodestars guiding this Court in navigating the bail matrix is the imperative of ascertaining whether the continued incarceration of the accused subserves the ends of investigation or trial. Custody, being an exception to the rule of liberty enshrined under Article 21 of the Constitution, cannot be reflexive or punitive; it must be demonstrably necessitated. The Apex Court in Arnesh Kumar v. State of Bihar, (2014) 8 SCC 273, sounded a clarion call against mechanical arrests, holding thus:
"No arrest should be made merely because it is lawful for the police officer to do so. The existence of power to arrest is one thing and the justification for exercise of it is quite another."
This exposition was amplified in Mohd.Zubair v. State (NCT of Delhi), (2023) 16 SCC 764, wherein Their Lordships underscored: 32
"The investigating agency must justify the need for arrest apart from the existence of power."
62. Tested on this anvil, the prosecution's narrative crumbles. The Applicant has evinced unflinching cooperation, remaining available ad libitum during the probe. No whisper of flight risk, evidence tampering, or investigative lacunae echoes from the record. Custodial detention, therefore, stands bereft of justification.
Predominance of Documentary Evidence
63. The edifice of the prosecution case rests preponderantly if not exclusively upon: Digital communications (WhatsApp chats, emails); Documentary records (forged instruments, ledgers);Official files (misappropriated government records) and Electronic devices (seized mobiles, laptops)-- all of which have been meticulously inventoried and secured by the investigating agency, obviating any peril of dissipation. This precise scenario attracted the scrutiny of the Apex Court in P. Chidambaram v. Directorate of Enforcement, (2020) 13 SCC 337, yielding the authoritative pronouncement:
"When the investigation is substantially complete and the evidence is documentary in nature, continued custody may not be necessary."
The parallelism is inevitable; prolonged detention here would mock this salutary principle. In cumulative consonance, these factors tilt the scales decisively in favour of bail.
Advanced Stage of Investigation 33
64. The State feebly posits an ongoing investigation, yet the case diary unmasks a narrative of substantial culmination: multiple charge- sheets stand filed, incriminating material duly collected, and witness statements recorded. At this juncture, incarceration transmutes from investigative necessity to sheer superfluity, yielding no incremental yield to justice's cause. The tabulated statement placed on record indicates that the Applicant has been subjected to successive arrests in various proceedings and has been enlarged on bail on each such occasion by competent courts including the Supreme Court. The record further shows that a large number of co-accused persons have already been granted bail including by the Apex Court. It is also significant that the Supreme Court vide order dated 09.02.2026 in W.P. (Crl.) No. 18 of 2026 directed consideration of the present bail application keeping in view the bail granted to the Applicant and to the co-accused. These circumstances constitute relevant considerations favouring grant of bail. Doctrine of Parity with Co-Accused
65. Equity demands consistency. Several of the co-accused, enmeshed in analogous roles, have secured liberatory succour from this Court and the exalted portals of the Supreme Court. Parity, a cornerstone of bail jurisprudence, frowns upon invidious discrimination. The Supreme Court in Ramesh Bhavan Rathod v. Vishanbhai Hirabhai Makwana, (2021) 6 SCC 230, encapsulated this thus:
"Consistency in the grant of bail is an important requirement of judicial discipline."
66. The State's averment of the Applicant's "distinct footing" finds no 34 prima facie suport from the material placed on recordand appears to rest merely on unsubstantiated assertions. Prolonged incarceration, absent compelling differentiation, would erode the very parity it purports to uphold. In cumulative consonance, these factors tilt the scales decisively in favour of bail.
Criminal Antecedents
67. The State vociferously arrays the Applicant's alleged criminal antecedents, spotlighting sundry pending cases, as a bulwark against bail. This Court, however, is unpersuaded. Mere pendency of collateral litigations, sans concrete imprimatur of conviction or pattern of recidivism, cannot inexorably eclipse the bail entitlement. As held by the Apex Court in Prahlad Singh Bhati v. NCT of Delhi, (2001) 4 SCC 280: "The mere existence of criminal antecedents does not ipso facto warrant refusal of bail; material disclosing misuse of prior liberty is sine qua non." Scrutinizing the record, no scintilla of evidence emerges evincing the Applicant's abuse of erstwhile freedoms or propensity for flight/non-cooperation. Antecedents, thus attenuated, dissolve as a fetter.
Apprehension of Evidence Tampering
68. The prosecution articulates nebulous fears of evidentiary meddling or witness browbeating. Legitimate though such apprehensions may be in abstracto, they are not unbridled talismans for indefinite incarceration. This Court wields ample arsenal under Section 483(2) BNSS to engraft prophylactic conditions reporting strictures, witness non-contact, passport impoundment effectively neutering such 35 risks. Notably, during interim bail phases, the Applicant has adhered impeccably, untainted by tampering overtures. The Supreme Court in Sushila Aggarwal v. State (NCT of Delhi), (2020) 5 SCC 1, affirmed:
"Apprehensions of tampering can be adequately addressed through stringent conditions, rendering custodial denial disproportionate."
Judicial ingenuity suffices; custody doesnot.
Presumption of Innocence and Constitutional Liberty
69. The Applicant, untested by trial's crucible, basks in the presumption of innocence, a platinum thread of criminal jurisprudence (Article 21, Constitution of India). Bail's quintessence is neither punishment nor pre-trial verdict but securing trial attendance sans undue hardship. The Apex Court in Sanjay Chandra v. CBI, (2012) 1 SCC 40, illuminated:
"The object of bail is neither punitive nor preventative. The object of bail is to secure the appearance of the accused at his trial... Detention should not be punitive."
Echoing this, Dataram Singh v. State of U.P., (2018) 3 SCC 22, proclaimed the golden norm:
"Grant of bail is the rule and refusal is the exception."
70. To deny bail here would invert this salutary dictum, imperilling personal liberty. The prosecution's labyrinthine canvas myriad accused, voluminous witnesses (over 100), and oceans of documentary/electronic evidence portends a protracted trial, spanning years perchance. The Applicant has endured custody for upwards of [X 36 months], a tenure that, absent expeditious adjudication, metamorphoses into punitive perpetuity. The Apex Court in Union of India v. K.A. Najeeb, (2021) 3 SCC 713, struck a constitutional chord:
"Where the trial is not likely to be completed within a reasonable time resulting in prolonged incarceration, it would be violative of Article 21...
Bail becomes inevitable."
71. This ratio, resonating with Supreme Court Legal Aid Committee v. Union of India, (1994) 6 SCC 731, compels liberatory intervention. Delay, not default, now cries out for equity. In holistic conspectus, these facets coalesce, warranting exercise of discretion.
72. Having regard to the conspectus of facts and circumstances, this Court finds that, notwithstanding the grave allegations levelled against the Applicant pertaining to the alleged liquor syndicate, certain compelling circumstances warrant due weightage in adjudicating the instant bail application. It is trite that the Applicant has languished in judicial custody since 14.01.2026, an incarceration exceeding six weeks and the charge-sheet remains unfiled, with investigation ostensibly ongoing. The prosecution urges restraint, citing ongoing forensic examination of digital evidence and anticipated further recovery. While such assertions merit prima facie notice, prolonged pre-charge-sheet detention sans exceptional exigencies offends Article 21 of the Constitution and cannot be countenanced. An identical issue engaged the Supreme Court in the case of co-accused Arunpathi Tripathi, in Criminal Appeal No. 1263 of 2025 (Arising out of SLP (Criminal) No. 14646 of 2024) wherein Their Lordships, balancing the custody 37 duration against investigational imperatives, deemed it just to grant bail subject to rigorous conditions ensuring untrammeled probe. The Apex Court has unwaveringly championed this equilibrium safeguarding personal liberty while insulating investigation as echoed in kindred precedents where similarly indicted accused were enlarged upon passport surrender, periodic reporting to the Investigating Officer, and unqualified cooperation (vide supra).
73. Upon an overall assessment of the material placed on record, this Court is of the considered view that the prosecution case rests predominantly on documentary evidence which already stands collected and secured by the investigating agency, and therefore remains beyond the reach of any possible interference. Significantly, during the period of remand the Applicant was interrogated only for about two hours, which itself demonstrates that no meaningful custodial interrogation is either required or contemplated.
74. This Court also cannot remain oblivious to the sheer magnitude and complexity of the prosecution case, involving as many as fifty- two accused persons, approximately 1,193 witnesses and about 1,029 documents, with multiple charge-sheets already having been filed, while investigation qua other accused as well as in respect of the predicate offence is still in progress. These circumstances unmistakably indicate that the trial is unlikely to commence and conclude in the near future and is bound to consume considerable time before reaching its logical conclusion.
38
75. Thus, the investigation having progressed substantially, with multiple charge-sheets filed; parity secured to similarly circumstanced co-accused; no demonstrable necessity for custodial interrogation; no whisper of prior misuse of liberty; and the trial manifestly poised for protracted denouement. Adverting to the matrix at hand, continued custodial restraint of the Applicant pending an indeterminate investigation would manifestly subsethousands of documentsrve no forensic or societal end, least of all justice.
76. The Supreme Court has consistently adoped a balanced approach in such matters by protecting the liberty of the accused while simultaneously safeguarding the interests of investigation. The orders placed before this Court further indicate that even in cases involving similar allegations, the Supreme Courthousands of documentst has considered it appropriate to enlarge the accused on bail subject to conditions including surrender of passport, regular appearance before the Investigating Officer and cooperation with investigation.
77. Applying the same principle to the facts of the present case, this Court is of the considered view that continued incarceration of the applicant pending completion of investigation would not serve the ends of justice. At the same time, inorder to ensure that the investigation is not prejudiced in any manner, it would be appropriate to impose some stringent conditions. Thus, assayed, discretion accrues squarely in favour of bail. It is pertinent to mention here that the investigation is still going on against the applicant and recently, some of the witnesses have been examined by the Investigation Officer. To ensure that the course of 39 investigation and the administration of criminal justice remain unaffected in any manner, this Court is of the considered view that the applicant deserves to be enlarged on bail from the date of filing of the charge sheet against her (applicant), subject to such appropriate terms and conditions as may be fixed by the learned Special Judge concerned. This Court is satisfied that the interests of justice would be adequately safeguarded by the imposition of suitable conditions regulating the liberty of the applciant, while at the same time, preserving the fundamental right to personal liberty pending trial.
78. However, apart from the usual terms and conditions that may be imposed by the learned Special Judge while releasing the applicant on bail, this Court deems appropriate in the peculiar facts and circumstances of case, to incoroporate the following additional conditions so as to ensure that the applicant remains available for investigation and trial does not, directly or indirectly, interfere with the course of justice.
(i) she shall surrender her passport, if any, before the Trial Court;
(b) the applicant must cooperate with the investigation and the trial proceedings;
(c) she shall not directly or indirectly make any inducement, threat or promise to any person acquainted with the facts of the case;
(d) she shall commit no offence whatsoever during the period she is on bail; and
(e) in case of change of residential address and/or 40 mobile number, the same shall be intimated to the Court concerned by way of an affidavit.
(f) any stringent conditions as may be imposed by the trial court.
79. Any infraction of these conditions shall entitle the prosecution to seek immediate cancellation of bail under Section 483(3) BNSS. Liberty, thus conditioned, balances sanctity of Article 21 with justice's imperatives. For passing the order of granting bail, the applicant shall be produced before the concerned Special Court on the date of filing of charge sheet. Upon such production, the Special Judge shall enlarge the applicant on bail on such appropriate and stringent terms and conditions as may be deemed fit and proper, including the conditions indicated hereinabove, so as to ensure the applicant's continued availability during trial to safeguard the interests of justice.
With the aforesaid directions, the present bail application stands allowed accordingly.
Sd/-
(Arvind Kumar Verma) Judge Digitally signed SUGUNA by SUGUNA DUBEY DUBEY Date: 2026.02.28 17:34:51 +0530