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2026 Supreme(Online)(Chh) 16225

HIGH COURT OF CHHATTISGARH AT BILASPUR
Ramesh Sinha, CJ
ABDUL MUNAF – Appellant
Versus
STATE OF C.G. – Respondent
MCRC No. 4207 of 2026



Advocates:
For the Appellants/Petitioners: Pawan Shrivastava
For the Respondents: Sourabh K. Pande

Regular bail may be granted in corruption cases where the investigation is complete, the charge-sheet is filed, the accused has no criminal antecedents, and there is no risk of tampering with evidence or influencing witnesses.

Headnote:The applicant sought regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, for offences punishable under Sections 7 and 12 of the Prevention of Corruption Act. The prosecution alleged that the applicant and a co-accused demanded a bribe of ₹25,000 from a complainant to avoid criminal implication, and the applicant was caught red-handed during a trap proceeding on 24.02.2026. The court noted that the investigation is complete and the charge-sheet was filed on 24.04.2026. The primary issue was whether the applicant is entitled to bail given the nature of the offence and the stage of the proceedings. The court reasoned that since the applicant has been in custody since 24.02.2026, has no prior criminal history, is already suspended from service, and the charge-sheet has been filed, there is no likelihood of tampering with evidence or influencing witnesses, and further custodial interrogation is not required. Accordingly, the bail application of the applicant is allowed

Table of Content
1. allegations of bribery and trap proceedings leading to arrest and charge-sheet. (Para 1 , 2)
2. contention regarding innocence and lack of demand versus direct involvement in a trap. (Para 3 , 4)
3. bail eligibility based on completion of investigation, lack of criminal history, and no risk of tampering. (Para 5 , 6)
4. grant of bail subject to specific conditions to ensure trial attendance. (Para 7 , 8 , 9)

Order on Board

11/05/2026

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. 11/2026 registered at Police Station- E.O.W. / Anti Corruption Bureau, Raipur, District- Raipur (C.G.) for the offence punishable under Sections 7 and 12 of Prevention of Corruption Act.

2. As per the prosecution case, a complaint was lodged by one Satyendra Kumar Prajapati before the OfÏce of Anti-Corruption Bureau, Ambikapur, alleging that the present applicant and co-accused, namely Guru Prasad Yadav, were demanding an amount of ₹25,000/- from the complainant for not implicating him in a criminal case. For verification of the complaint, a digital voice recorder was provided to the complainant, in which the conversation regarding the demand of ₹25,000/- by the co-accused was recorded. Thereafter, a trap proceeding was planned for 23.02.2026. Subsequently, on 24.02.2026, the applicant/accused called the complainant and asked him to pay the bribe amount as decided by the co-accused. Thereafter, on 24.02.2026, the applicant/accused was caught red-handed while accepting the bribe amount of ₹25,000/-, and thereafter, he was arrested. On the basis of the evidence available against the applicant and the co-accused, a Zero FIR was registered by the Anti-Corruption Bureau, Unit Ambikapur, and subsequently Crime No. 11/2026 for the offences punishable under Sections 7 and 12 of the Prevention of Corruption Act, 1988 (as amended in 2018) was registered at Police Station E.O.W./A.C.B., Raipur. After completion of the investigation, the charge-sheet was filed on 24.04.2026.

3. Learned counsel for the applicant submits that the applicant is innocent and has been falsely implicated in the present case. It is further submitted that no complaint has been made against the present applicant and he has never demanded any bribe from any person. He further submits that, as per the prosecution case itself, the allegation regarding demand of ₹25,000/- pertains to the co-accused, namely Guru Prasad Yadav, and no allegation of demand of bribe has been levelled against the present applicant. It is also submitted that the involvement of the applicant has been alleged only during the course of the trap proceedings conducted by the Anti-Corruption Bureau, and the said proceedings, including the alleged recovery and other related aspects, are matters of evidence which are required to be proved during the course of trial. He further submits that the investigation has already been completed and the charge-sheet has been filed before the competent Court therefore, there is no possibility of the applicant interfering with the prosecution evidence, and no useful purpose would be served by keeping him in judicial custody. It is also submitted that the applicant is in custody since 24.02.2026, he is the sole earning member of his family, and his continued detention has caused severe financial and social hardship to his dependent family members. It is further submitted that no prior allegations have ever been made against him and now he has been suspended from services further he has no criminal antecedent and the trial is likely to take some time for its conclusion. Therefore, he prays for grant of bail to the applicant.

4. On the other hand, learned State Counsel appearing for the respondent/State opposes the bail application and submits that in the present case, charge-sheet h

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