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2026 Supreme(Raj) 219

IN THE HIGH COURT OF JUDICATURE FOR RAJASTHAN AT JAIPUR
ASHOK KUMAR JAIN, J.
Jeetram S/o Sitaram – Appellant
Versus
The State of Rajasthan – Respondent
S.B. Criminal Miscellaneous Bail Application No. 4226 of 2026
Decided On : 01-05-2026

Advocates Appeared:
For the Appellant : Sikandar Singh Sakkarwal
For the Respondent: Vijay Singh Yadav

Bail may be granted to an accused in a corruption case where the investigation is complete, the charge sheet has been filed, and the accused has been in custody for a significant period, provided the trial is expected to be prolonged and conditions are imposed to ensure judicial integrity.

Headnote:(A) Bharatiya Nagarik Suraksha Sanhita, 2023 - Section 483 - Prevention of Corruption Act, 1988 - Section 7 - Bail application - Accused charged with accepting illegal gratification - Investigation complete and charge sheet filed - Accused in custody for significant duration - Trial likely to take time - Grant of bail - Conditions imposed. (Paras 1, 3, 6, 7, 8)

Facts of the case:
The applicant, a public servant, was arrested for allegedly accepting a bribe. The prosecution alleged that the applicant was caught red-handed. The applicant contended that the case was fabricated, there was no demand for gratification, and no official work was pending. The investigation has concluded, and the charge sheet has been submitted to the trial court.

Findings of Court:
The court observed that the investigation is complete and the applicant has been in custody for a considerable period. Given that the trial is expected to be protracted, the court deemed it appropriate to release the applicant on bail, subject to specific conditions to ensure cooperation and prevent interference with the judicial process.

Issues: Whether the applicant is entitled to bail given the completion of the investigation and the nature of the allegations.

Ratio Decidendi: Bail is granted when the investigation is complete, the accused has been in custody for a sufficient duration, and the trial is unlikely to conclude expeditiously, provided that the accused adheres to conditions ensuring the integrity of the trial.

Result: Bail application allowed.

Table of Content
1. factual context of arrest and charges. (Para 1 , 6)
2. adversarial contentions regarding bail. (Para 2 , 3 , 4)
3. judicial reasoning for granting bail. (Para 5 , 7)
4. operative order and conditional release terms. (Para 8 , 9)

ORDER :

1. The present bail application under Section 483 of BNSS is filed by the applicant-accused Jeetram S/o Sitaram seeking bail in respect of a criminal case registered as FIR No.43/2026 dated 14.02.2026 registered at P.S. C.P.S. Jaipur, ACB District, for the offence under Sections 7 of Prevention of Corruption Act.

2. Learned counsel for the applicant submits that the applicant has been falsely implicated in the matter and the investigation against him is complete and he is no more required in investigation. He further submits that there are no chance of fleeing of applicant accused from the jurisdiction of this Hon’ble Court. He also submits that the applicant undertakes not to repeat offence and cooperate with investigation/trial, which will take time.

3. Learned counsel for petitioner submits that on a false complaint, the present petitioner, who was working as Constable at Police Station Gumanpura, Kota, was caught red-handed accepting bribe of Rs. 3,000. He further submitted that neither there was any demand nor any work was pending with the petitioner and a false case has been registered against him. He also submitted that the petitioner is in custody since 10.02.2026 and now a charge sheet has been filed.

4. Learned Public Prosecutor has vehemently opposed the bail application and submitted that the allegations are grave and serious in nature.

5. Heard learned counsel for the petitioner-accused and learned Public Prosecutor. Perused the material placed on record by both the parties.

6. On the basis of a complaint made by Shanu Khan regarding alleged demand of bribe, the petitioner was trapped and caught red-handed by the ACB unit of Kota. The petitioner was arrested on 10.02.2026 and after investigation, a charge sheet has been filed. At the time of interception and arrest, the petitioner was working as Constable and the recovered amount was Rs. 3,000/-.

7. Upon hearing the arguments and perusing the record, we have found that the applicant-accused is no more required in the investigation and he is in custody for quite some time. The further proceedings will take its own time, therefore, looking to entirety of facts and circumstances of the case and without expressing any opinion on merits of the case, the Court deems it appropriate to grant bail to the applicant-accused.

8. Thus, the instant bail application filed on behalf of applicant-accused Jeetram S/o Sitaram, is hereby allowed and the applicant-accused is ordered to be released on bail upon furnishing a personal bond of Rs. 50,000/- with two sureties of like amount to the satisfaction of the Trial Court with the following conditions:-

(i) The applicant-accused shall not tamper with evidence or influence the witness in any manner.

(ii) The applicant-accused shall not indulge in any criminal activity and shall not repeat any criminal offence punishable under the Law.

(iii) The applicant-accused shall attend the hearing of the Trial Court on the date fixed by the Trial court or as and when asked to appear before the Trial Court.

(iv) In case of any violation of above conditions, the bail granted to the applicant-accused shall be liable to be canceled.

9. The Registry is directed to send a copy of this order to the Trial Court through E-mail.

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