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2026 Supreme(Online)(MP) 2569

IN THE HIGH COURT OF MADHYA PRADESH AT JABALPUR
Sandeep N. Bhatt, J
Ramendra Sharma – Appellant
Versus
The State Of Madhya Pradesh – Respondent
MISC. CRIMINAL CASE No. 54042 of 2025 | MCRC-54042-2025



Advocates:
For the Appellants/Petitioners: Sheshraj Kushwaha
For the Respondents: K.S. Baghel

Grant of anticipatory bail based on the principle of parity, extending the benefit of a Supreme Court order to an applicant facing similar allegations of misappropriation in a related set of cases.

Headnote:The applicant sought anticipatory bail under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023, in connection with Crime No. 80/2025 for offences under Sections 318(2), 316(5), and 61(2)(a) of the BNS 2023. The prosecution alleged that the applicant, an In-Charge in an Issue Centre, colluded with other officials and agents to reduce the quantity of paddy and misappropriate the minimum support price. The court found that the applicant's situation was similar to other cases where the Apex Court had already granted protection. The primary issue was whether the applicant was entitled to anticipatory bail based on parity with a Supreme Court order. The court reasoned that since the Hon'ble Apex Court in the case of Aman Rajiv Chhabra Vs. State of Madhya Pradesh (SLP (Cr.) No. 15170/2025) had directed that no coercive action be taken against petitioners cooperating with the investigation in a similar set of matters, the same benefit should be extended to the present applicant. The anticipatory bail application filed by the applicant is allowed.

Table of Content
1. application for anticipatory bail regarding allegations of paddy misappropriation and msp fraud. (Para 1 , 2)
2. reliance on supreme court precedent to establish parity for the grant of bail. (Para 3 , 4 , 5)
3. grant of anticipatory bail subject to specific conditions and bond requirements. (Para 6 , 7 , 8 , 9)

ORDER

This is the first application filed on behalf of the applicant under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS) for grant of anticipatory bail apprehending his arrest in relation to Crime No.80/2025 registered at Police Station - Gorabazar, District Jabalpur (M.P.) for the offence punishable under Sections 318(2), 316 (5), 61 (2) (a) of BNS 2023 .

2. As per the prosecution story, the allegation against the present applicant, who is the In-Charge in Issue Centre, in local office of MPSCSC, Richhai in collusion with the Society issue center, concerned officer, traders and commission agents, reduced the quantity of paddy and then after taking possession of paddy, they got challan of truck and thereafter also misappropriated in the quantity of paddy and thereby misappropriated minimum support price of paddy. On the basis of aforesaid allegation, F.I.R was registered.

3. Learned counsel for the applicant submitted that applicant is innocent. He has been falsely implicated in the said offence. He has relied on the order dated 19.12.2025 passed by the Apex Court in same set of matter, of course, in different F.I.R in S.L.P (Cr.) No.15170/2025 and has submitted that facts of the present case are almost identical. There is no need of custodial interrogation of present applicant. The conclusion of trial will take considerable time. In these circumstances, applicant may be granted anticipatory bail.

4. On the other hand, learned counsel for the State has fairly submitted that the Hon'ble Supreme Court has passed the order dated 19.12.2025 in SLP(Cr) No.15170/2025 in the cases relating to Samity Prabhandhak (Society Manager).

5. The Hon'ble Apex Court in the case of Aman Rajiv Chhabra Vs. State of Madhya Pradesh SLP (Cr.) No.15170/2025 dated 19.12.2025 has passed the following order :-

"1. Heard learned counsel for the parties.

2. In pursuance of the orders of this court, the petitioners have been appearing in the investigation and are cooperating with the investigating officer (I.O).

3. In view of the aforesaid, the interim orders dated 08.09.2025, 17.10.2025 and 16.10.2025 are made absolute and it is provided that no coercive action shall be taken against the petitioners, if they continue to co-operate and participate in the investigation.

4. In the event of arrest, the petitioners shall be enlarged on bail on such terms and conditions as may be imposed by the Arresting Officer.

5. The Special Leave Petitions stand disposed of. Pending applications(s), if any, shall also stand disposed of."

6. Considering the aforesaid, I am of the view that the same benefit should be granted to the present applicant on the terms and conditions mentioned in the above order.

7. Looking to the facts and circumstances of the case, without commenting anything on the merits of the case, the anticipatory bail application filed by the applicant is allowed. It is directed that if the applicant is arrested by the police then he shall be released on bail on his furnishing a personal bond in the sum of Rs.50,000/- (Rs. Fifty Thousand only) with one solvent surety of the like amount to the satisfaction of the Investigating Officer/Arresting Authority.

8. Applicant shall abide by the following conditions under Section 480 (2) of Cr.P.C :-

(a) Applicant shall make himself available for interrogation by a Police Officer as and when required;

(b) He shall not, directly or indirectly, make any inducement, threat or promise to complainant or witnesses;

(c) He shall not leave India without the previous permission of the Court;

(d) He shall not commit similar offence, of which, he is accu

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