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2026 Supreme(Online)(Chh) 10661

HIGH COURT OF CHHATTISGARH AT BILASPUR
Ramesh Sinha, CJ
SATYENDRA DIWAKAR – Appellant
Versus
STATE OF CHHATTISGARH – Respondent
MCRC No. 3648 of 2026



Advocates:
For the Appellants/Petitioners: Sumit Singh Rathore
For the Respondents: Sourabh K. Pande

Regular bail may be granted in corruption cases when the investigation is complete, the charge-sheet is filed, the accused has no prior criminal history, and there is no risk of tampering with evidence.

Headnote:(A) Criminal Law - Bail - Regular Bail - Investigation complete and charge-sheet filed - Where the applicant has no criminal antecedents, has already been suspended from service, and the charge-sheet has been filed, the likelihood of tampering with evidence or influencing witnesses is minimal, justifying the grant of bail. (Para 6)

Issues: Whether the applicant is entitled to regular bail after the filing of the charge-sheet in a case registered under the Prevention of Corruption Act.

Table of Content
1. allegations of bribery and the execution of a trap by the anti-corruption bureau. (Para 1 , 2)
2. contention of false implication versus the prosecution's reliance on the trap and charge-sheet. (Para 3 , 4)
3. grant of bail based on completion of investigation, lack of criminal history, and absence of need for custodial interrogation. (Para 5 , 6)
4. order for release on bail subject to specific conditions to ensure trial attendance. (Para 7 , 8 , 9)

Order on Board

1. This is the first bail application filed under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (for short ‘BNSS’) for grant of regular bail to the applicant who has been arrested in connection with Crime No. 04/2026 registered at Police Station Anti Corruption Bureau, Unit Bilaspur, District- Bilaspur (C.G.) for the offence punishable under Sections 7 of Prevention of Corruption Act.

2. As per the prosecution story, the complainant, namely Shyamta Prasad Tandon, is a friend of Dukhiram, who is the son of Vedram. On 21.01.2026, the complainant Shyamta Prasad Tandon submitted an application before the Deputy Superintendent of Police, Anti-Corruption Bureau, District Bilaspur (C.G.), alleging that the father of his friend, namely Vedram, is the owner of an agricultural land bearing Khasra No. 981, admeasuring 0.2270 hectares, situated at Village Darri, District Korba. It is further alleged that due to his ill health, Vedram requested the complainant to approach the ofÏcials of CSPDCL for installation of a transformer on his land. Accordingly, after receiving the application from Vedram, the complainant along with Dukhiram visited the CSPDCL ofÏce at Dipka and submitted the application on 25.12.2025. After three days, the present applicant, who was posted as Assistant Engineer at CSPDCL, Dipka, District Korba (C.G.), accompanied them and inspected the said agricultural land. Subsequently, on the next day i.e. 20.01.2026, Dukhiram met the applicant in his ofÏce, where the applicant allegedly instructed him to deposit an ofÏcial challan amount of Rs. 90,000/- (Rupees Ninety Thousand) for installation of the transformer and further demanded a separate amount of Rs. 80,000/- (Rupees Eighty Thousand) as illegal gratification (for “tea and water”). Thereafter, Dukhiram allegedly paid a sum of Rs. 30,000/- to the applicant and sought time to pay the remaining amount. Thereafter, on 21.01.2026, the complainant lodged a complaint before the Anti-Corruption Bureau, District Bilaspur, narrating the entire incident. Acting upon the said complaint, the ACB ofÏcials laid a trap to apprehend the applicant red-handed. For this purpose, a voice recorder was provided to the complainant to record the conversation regarding the demand and acceptance of bribe. Pursuant thereto, the complainant again met the applicant with the tainted currency notes, which had been treated with chemical powder by the ACB ofÏcials. The complainant handed over the said tainted notes to the applicant. Immediately thereafter, the ACB ofÏcials entered the ofÏce of the applicant and recovered the said currency notes from beneath the desk of the applicant. Consequently, a crime has been registered against the applicant under Section 7 of the Prevention of Corruption Act and he has been arrested in connection with the aforesaid offence.

3. Learned counsel for the applicant submits that the applicant is innocent and has been falsely implicated in the present case. It is contended that the applicant has neither committed nor been involved in the alleged offence and has been roped in merely on the basis of false and concocted allegations. It is further submitted that the applicant never demanded any illegal gratification from the complainant, rather, it was the complainant who was repeatedly attempting to induce the applicant to expedite the work and was himself offering money illegally, which was consistently refused by the applicant. The amount allegedly recovered was not to

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