1 2026:CGHC:11111 NAFR HIGH COURT OF CHHATTISGARH AT BILASPUR ORDER RESERVED ON 04.02.2026 ORDER DELIVERED ON 03.03.2026 ORDER UPLOADED ON 03.03.2026 MCRC No. 10445 of 2025 1 - Nitesh Purohit S/o Bhanu Shankar Purohit Aged About 52 Years R/o B-1, Mukta Sadan, In Front Of Goyal Nursing Home Samta Colony, District- Raipur Chhattisgarh, ... Applicant(s) versus 1 - State Of Chhattisgarh Through ACB/ EOw, District- Raipur Chhattisgarh, ... Respondent(s) For Applicant(s) : Shri Manoj Paranjape, Senior Counsel assisted by Shri Gagan Tiwari, Advocate For Respondent/State : Shri Praveen Das, Addl. Advocate General assisted by Shri Krishna Gopal Yadav, GA (Hon’ble Shri Justice Arvind Kumar Verma) C A V Order 2 The instant application is preferred by the applicant seeking grant of regular bail in connection with FIR No. 04/2024 registered at Police Station EOW/ACB, Raipur, pertaining to offences punishable under Sections 420, 467, 468, 471 and 120B IPC as well as Sections 7 and 12 of the Prevention of Corruption Act, 1988. Bail application filed before the learned Special Judge (Prevention of Corruption Act), Raipur came to be rejected vide order dated 10.12.2025, which order is impugned herein. BRIEF FACTS OF THE CASE 2. The prosecution case, in nutshell, revolves around an alleged liquor scam in Chhattisgarh unearthed during Income Tax search and seizure operations conducted in February-March 2020 at multiple premises linked to liquor trade entities and associated individuals. The documents and digital records allegedly recovered therein purportedly revealed irregular financial transactions and systemic manipulations in State liquor procurement, distribution, licensing, and sales processes, pointing to an organized syndicate influencing official mechanisms. Statements of sundry persons recorded by Income Tax authorities lent further credence to these inferences, precipitating deeper scrutiny. On 18.11.2022, the Directorate of Enforcement registered ECIR under PMLA, treating the proceeds as arising from scheduled offences. Pursuant thereto, communication under Section 66 PMLA was addressed to EOW/ACB, Raipur, culminating in FIR No. 04/2024 dated 07.01.2024 under Sections 420, 467, 468, 471, 120B IPC and Sections 3 7 & 12 PC Act, 1988, arraying public servants and private players in the liquor business. 3. The conspiracy envisaged illicit gains through: (i) commissions extracted from suppliers for liquor supply/sale clearances; (ii) off-the- record liquor sales via government outlets abetted by multi-level manipulations; and (iii) annual payoffs securing seamless distillery operations. The generated funds were allegedly laundered via a web of intermediaries involving transit, storage, and disbursement through sundry premises. Voluminous documents, financial trails, witness statements, and digital evidence were garnered. Initial Final Report was filed before Special Court (PC Act), Raipur, followed by successive supplementary charge-sheets implicating more accused; the applicant featured in the sixth such report dated 24.11.2025. 4. The applicant stands indicted for abetting principal accused in syndicate operations, with his/family premises allegedly leveraged for fund handling/transport linked to excise irregularities, alongside business entities under his umbrella facilitating syndicate logistics. Summoned and arrested on 19.09.2025, he was charge-sheeted inter alia. Prosecution posits concert with co-accused in a broader conspiracy yielding illicit excise profits, backed by extensive witness examinations and documentary matrix, to be substantiated at trial. SUBMISSION OF THE COUNSEL FOR THE APPLICANT 5. Shri Paranjape, learned Senior counsel for the applicant submits that the instant bail application merits gracious consideration in light of 4 triple test enshrined in bail jurisprudence, duly satisfied herein. No further Investigative Utility Probe qua the applicant stands concluded with filing of 6th Supplementary Final Report dated 24.11.2025. No custodial remand remains warranted, rendering continued incarceration otiose and punitive. There is no discrete role or overt act stands attributed to the applicant in charge-sheet or materials garnered. The association, if any, remains vicarious and inferential, insufficient to justify pre-trial deprivation of liberty. He has placed his reliance in the matter of State of Kerala v. Raneef, (2011) 1 SCC 784). 6. Learned Sr. counsel for the applicant submits that the applicant has been in judicial custody since 19.09.2025 and investigation qua him stands substantially completed, culminating in filing of supplementary charge sheet. The Investigation, insofar as the present applicant is concerned, stands completed and the investigating agency has already filed the 6th Supplementary Final Report dated 24.11.2025 before the learned Special Judge (Prevention of Corruption Act), Raipur. Thus, the applicant is no longer required for custodial interrogation and continued detention serves no investigative purpose. The trial Court rejected the bail application primarily on the gravity of allegations without properly appreciating absence of specific role attributed to the applicant, completion of investigation, documentary nature of evidence, parity with co-accused already enlarged on bail, prolonged and uncertain timeline of trial. It is therefore submitted that seriousness of accusation alone cannot justify indefinite incarceration pending trial. 5 7. It has been contended that the constitutional courts retain power to grant bail despite statutory rigours. As has been held by the Supreme Court in Union of India v. K.A. Najeeb (2021) 3 SCC 713, stating that Statutory restrictions… do not oust the ability of constitutional courts to grant bail on grounds of violation of Part III of the Constitution… Where there is no likelihood of trial being completed within reasonable time, courts may grant bail.” 8. The allegations against the applicant are general and omnibus in nature and do not attribute any specific overt act or transaction showing direct handling or personal receipt of alleged illegal funds. No recovery of cash, incriminating documents or financial instruments has been effected from the applicant despite allegations of large scale cash movement. 9. It is next submitted that the applicant’s name appears in the FIR without assigning any specific overt act. Even in the supplementary charge-sheet, allegations remain broad and inferential in nature. No direct recovery of illegal proceeds has been made from the applicant and no material demonstrates applicant’s personal handling or receipt of alleged illegal funds. The entire case of the prosecution is based on documentary evidence, financial records and statements already recorded. All the documents and electronic material relied upon stand seized and are in custody of the prosecution. Therefore, there is no possibility of tampering with evidence. 6 10. It is contended that the applicant has throughout cooperated with investigating agencies. He appeared before authorities whenever summoned and complied with directions of Courts and had never attempted to evade investigation or abscond. The arrest took place when he appeared before the agency pursuant to notice, demonstrating his bona fides. The prosecution case involves large number of accused persons, voluminous documentary record, several hundreds of witnesses and the charges are yet to be framed. The trial in such complex economic matters ordinarily takes several years and continued detention would therefore amount to punishment prior to conviction. 11. Next contention of the learned Senior Counsel for the applicant is that several co-accused persons, including those alleged to have played more significant roles, have already been granted bail by competent courts. The persons allegedly involved in core operational and financial aspects of the case are already on bail. Therefore, denial of bail to the applicant alone would violate the principle of parity. The applicant has no criminal antecedents. He is a permanent resident and engaged in lawful business activities. There is no possibility of absconding or fleeing from justice. 12. Prosecution witnesses are largely official or formal witnesses and the evidence is documentary in nature. Hence, apprehension of influencing witnesses is illusory. It is settled law that an accused is presumed innocent until proven guilty. The pre-trial detention should not become punitive. He submits that the liberty guaranteed under Article 21 of the Constitution mandates that detention pending trial must be 7 justified by compelling circumstances, which are absent here. He contended that the applicant has remained in custody since September 2025 and trial involving enormous documentary and oral evidence will take years and further has placed reliance in the matter of Manish Sisodia v. Directorate of Enforcement (2024) SCC OnLine SC 920, which is as under: “Bail is not to be withheld as a punishment… It appears that the trial courts and the High Courts attempt to play safe in matters of grant of bail… Bail is a rule and refusal is an exception… It is high time that the trial courts and the High Courts recognize the principle that bail is rule and jail is exception.” 13. Similarly, authority has been placed in the matter of Manish Sisodia Vs. CBI, 2023 SCC OnLine SC 1393 wherein it was observed that prolonged incarceration is violation of Article 21. In yet another decision of the Supreme Court, ie. Javed Gulam Nabi Shaikh Vs,. State of Maharashtra, (2024) 9 SCC 813, it has been held that “Seriousness of the offence cannot justify denial of bail where trial is unlikely to conclude within reasonable time.” 14. The allegations attributed to the present applicant are broad, omnibus and lacking in material particulars. Even according to the prosecution narrative, the applicant is stated to have been “involved in arrangements and movement of funds”, yet no specific transaction is disclosed, no particular date, time or place is mentioned, no amount is attributed, no recipient or beneficiary is identified, no circumstance 8 demonstrating active participation is established. Such generalized allegations cannot constitute prima facie proof of involvement in offences of conspiracy,cheating or corruption. 15. In bail jurisprudence, vague assertions cannot justify continued incarceration in absence of concrete material linking the accused to the criminal acts. The allegations attributed to the applicant are sweeping and general in nature, without identification of any specific transaction, role performed, amount handled, beneficiary involved or direct participation. Bail stage requires existence of prima facie material, not mere suspicion or association. It is settled that detailed examination of evidence is impermissible at the stage of bail. He has placed his reliance in the matter of Niranjan Singh & Anr. v. Prabhakar Rajaram Kharote & Ors.(1980) 2 SCC 559, wherein it has been held as under: “Detailed examination of the evidence and elaborate documentation of the merits should be avoided while passing orders on bail applications… To be satisfied about a prima facie case is needed but it is not the same as an exhaustive exploration of the merits.” 16. It is next contended that the applicant has been suffering from chronic schizophrenia for nearly three decades, requiring continuous psychiatric supervision, medication and periodic clinical evaluation. Medical records and treatment documents issued by treating psychiatrists have already been placed on record. Adequate 9 psychiatric treatment is not available within jail conditions, and incarceration has seriously impacted applicant’s mental stability and safety. Thus, continued custody poses grave risk to his health and personal well-being. He further submits that trial in the present case, involving numerous accused persons, voluminous records, and hundreds of witnesses, is unlikely to conclude within reasonable time. 17. Reliance is placed upon Manish Sisodia v. Directorate of Enforcement, 2024 SCC OnLine SC 920, wherein the Apex Court reiterated: “Bail is not to be withheld as punishment… bail is rule and refusal an exception.” 18. Reliance is also placed on Javed Gulam Nabi Shaikh v. State of Maharashtra, (2024) 9 SCC 813, wherein it was held that prolonged incarceration without likelihood of early trial violates constitutional liberty. 19. Further reliance is placed on Union of India v. K.A. Najeeb, (2021) 3 SCC 713, wherein the Supreme Court has held that: “Statutory rigours cannot fetter constitutional courts from granting bail where trial is unlikely to conclude within reasonable time.” 20. Bail is therefore warranted not merely on legal grounds but also on humanitarian considerations, ensuring access to proper medical care under supervision of family and medical professionals. A substantial portion of prosecution allegations is sought to be supported by alleged WhatsApp chats. Reliance placed by prosecution upon 10 Whatsapp chats and digital material is legally questionable at this stage, as seizure, custody chain and certification requirements under law are disputed issues to be tested during trial. It is contended that at the stage of bail, the Courts are not expected to conduct a detailed examination of evidence. Reliance is placed on Niranjan Singh Vs. Prabhakar Rajaram Kharote (1980) 2 SCC 559, wherein the Apex Court has observed that : “Detailed examination of the evidence and elaborate documentation of the merits should be avoided while passing orders on bail applications…” 21. Further reliance is placed on P. Chidambaram v. CBI, (2020) 13 SCC 337, wherein it was held: “At the stage of granting bail, elaborate examination of evidence and detailed reasons touching upon merits of the case should be avoided…” 22. However the mobile devices were not seized by the investigating agency, no proper custody chain has been demonstrated, no forensic extraction report has been produced, chats are stated to have been sourced from Income Tax authorities without authentication and no certification under Section 65B of the Evidence Act has been produced. 23. In absence of lawful seizure, forensic verification, and certification, such electronic material cannot presently be treated as legally admissible evidence. Selective reproduction of alleged messages without establishing source, integrity, and authenticity 11 renders such material unreliable. In absence of legally admissible electronic evidence, allegations against the applicant remain unsubstantiated. 24. It is significant that no incriminating material whatsoever has been recovered from the applicant. No unaccounted currency, documents, diaries, banking instruments, digital records or valuables have been seized from him. If the prosecution theory of large-scale movement of funds through the applicant were true, at least some traceable recovery would have surfaced. The total absence of recovery demolishes the prosecution’s attempt to link the applicant with alleged financial transactions. Mere association or familial linkage with other accused persons cannot constitute criminal liability. Even if prosecution allegations are assumed at face value, essential ingredients of offences alleged are not satisfied. There is no material to show the dishonest inducement, forgery or fabrication of records, personal benefit derived by applicant, criminal intent or participation. The allegations are restricted to alleged harbouring or facilitating movement of funds without demonstrating culpable intent. 25. Consequently, prima facie ingredients of offences under Sections 420, 467, 468 IPC and Section 12 of the Prevention of Corruption Act are not made out. The prosecution seeks to project disputed materials as conclusive proof, whereas at bail stage courts are only required to see existence of prima facie case without entering into merits. He has placed reliance in the matter of P. Chidambaram v. Central Bureau 12 of Investigation, (2020) 13 SCC 337 wherein it has been observed that “At the stage of granting bail, elaborate examination of evidence and detailed reasons touching upon the merits of the case should be avoided as the same may prejudice the accused.” 26. Pre-trial incarceration ought not degenerate into punitive detention, a consistent exposition of the Apex Court jurisprudence. The applicant has extended full cooperation throughout, poses no flight risk, faces exclusively documentary evidence, and confronts a concluded investigation. Continued custody is, thus, ex facie unjustified and liable to be discountenanced. The allegations remain nebulous and bereft of specificity; no recoveries implicate the applicant; electronic evidence is inherently suspect; mens rea stands unestablished; incarceration duration impugns Article 21 safeguards; trial commencement looms indefinitely; and settled precepts mandate a liberal bail dispensation. 27. In view of the settled juridical postulates and unimpeachable facts canvassed, the applicant justly merits enlargement on bail. SUBMISSIONS ON BEHALF OF THE RESPONDENT/STATE 28. Learned State counsel submits that the allegations pertain to a large-scale organized criminal conspiracy involving manipulation of the State liquor trade, illegal commission collection, diversion of government revenue, and systematic generation and distribution of proceeds of crime running into thousands of crores. 13 29. The present applicant is not a peripheral or casual participant but has emerged during investigation as a trusted custodian and operational facilitator of tainted cash forming a crucial link in the conspiracy. Considering the magnitude, organized structure, and continuing investigation into financial trails, the present case stands in a category where grant of bail would seriously prejudice ongoing investigation. 30. The investigation initiated on the basis of inputs received from the Enforcement Directorate revealed existence of a structured syndicate involving influential individuals, officials and private actors who manipulated liquor procurement, distribution and licensing processes within the State. The conspiracy resulted in generation of illegal proceeds through collection of illegal commission from liquor suppliers, sale of unaccounted liquor through State-run outlets using fake holograms, extraction of illegal gratification from distilleries to permit business operations, diversion of lawful State revenue. These acts caused enormous financial loss to the State exchequer and enriched the conspirators. 31. He contended that the investigation reveals that the syndicate, led by co-accused Anwar Dhebar and others, generated and distributed large amounts of illegal cash through controlled channels. The present applicant, being a close and trusted associate of key conspirators, was entrusted with custody, storage and distribution of tainted funds. Cash was routinely brought in bags by associates and shifted into premises linked with the applicant, including Hotel Giriraj, 14 from where onward distribution was undertaken. The applicant, along with his son, facilitated safe storage and subsequent delivery of illegal cash at designated locations as per instructions received from syndicate leaders. Investigation further discloses that co-accused persons used the applicant’s premises as a safe-house for movement and concealment of proceeds of crime. Statements of co-accused and other witnesses corroborate that tainted money was kept at premises controlled by the applicant. 32. The technical analysis of digital material including WhatsApp communications establishes coded instructions relating to delivery and disbursement of illegal funds. Chats contain coded references to recipients, amounts and delivery points, demonstrating structured financial operations and the ledger-type digital entries and date-wise payment charts correlate with communications showing organized cash distribution mechanisms. The entries reveal repeated large-value payments routed through channels linked with the applicant. Such digital correlation establishes prima facie involvement of the applicant in custody and movement of illegal funds. 33. It is contended that the investigation so far reveals that illegal commissions and revenue diversion arising out of liquor operations have resulted in generation of proceeds exceeding several thousand crores. Consolidated analysis indicates illegal commission from country liquor operations amounting to thousands of crores, illegal commissions in foreign liquor operations, illegal gains arising from misuse of licensing framework and cumulative financial impact exceeding ₹3,000 15 crores and investigation suggesting further escalation. Such magnitude places the offence among the gravest economic crimes affecting public revenue. 34. He submits that the investigation is multi-layered and continuing to trace beneficiary chains, money trails and investments. Multiple supplementary charge-sheets have already been filed and investigation continues regarding additional aspects. Mere filing of charge-sheet against some accused does not conclude investigation in such complex economic crimes. Further tracing of assets, proceeds of crime, and financial linkages is ongoing. 35. The applicant occupies a position enabling influence over persons connected with cash handling and delivery mechanisms. Material witnesses include persons directly connected with financial movement and operational execution and therefore the release of the applicant poses grave risk of influencing or intimidating witnesses and tampering with documentary and digital evidence. The applicant also possesses capability to obstruct financial tracing by altering asset structures or frustrating attachment proceedings. In connected proceedings arising from the same conspiracy, this Court has recorded categorical findings regarding organized criminal activities and likelihood of influence over witnesses. The observations made therein regarding involvement of accused persons carry persuasive value and reinforce seriousness of allegations. 16 36. He submits that the economic offences involving diversion of public revenue and organized corruption strike at the economic foundation of governance. The Courts have repeatedly recognized that economic crimes require serious consideration at bail stage owing to their societal impact. The present offence involves systematic siphoning of State revenue through manipulation of public systems. Defence claims regarding absence of recovery or alleged infirmities in electronic evidence are matters for trial and cannot dilute prima facie findings at bail stage. Health grounds raised by the applicant can be adequately addressed within custodial medical framework. Alleged cooperation during investigation does not mitigate gravity of involvement and investigation remains ongoing, the financial trails remain under examination. Witnesses are yet to be examined therefore the release of applicant would adversely affect investigation and trial. 37. The applicant is prima facie a key facilitator in custody and movement of proceeds of crime and the offence involves enormous public revenue loss. He submits that the investigation remains incomplete and possibility of influence and tampering exists. Therefore, grant of bail at this stage would seriously prejudice investigation and trial. In view of the facts and circumstances stated hereinabove, it is respectfully prayed that this Court may be pleased to reject the bail application filed by the applicant in the interest of justice. FINDINGS AND CONCLUSION 17 38. After hearing arguments from the learned counsel for both sides, reviewed the case file meticulously, in essence. 39. The present application necessitates examination of competing considerations, seriousness of allegations on one hand and constitutional protection of personal liberty on the other within the settled framework governing grant of bail. 40. While the seriousness of allegations cannot be understated, the scope of consideration at the stage of bail is limited and does not involve a detailed appreciation of evidence which is the domain of trial. I. Principles Governing Grant of Bail 41. The law governing bail is well settled. The Apex Court has consistently held that grant or refusal of bail must be governed by judicial discretion exercised on settled parameters balancing individual liberty with societal interest. In State of Rajasthan v. Balchand (1977) 4 SCC 308, the Apex Court laid down the foundational principle that “bail is the rule and jail is the exception.” 42. This principle was reiterated and elaborated in Gudikanti Narasimhulu v. Public Prosecutor (1978) 1 SCC 240, wherein the Court emphasized that deprivation of liberty pending trial must be justified by compelling reasons and cannot be mechanical. 43. Similarly, in Sanjay Chandra v. CBI (2012) 1 SCC 40, dealing with economic offences involving large financial implications, the Apex Court observed that seriousness of allegation alone cannot justify 18 prolonged pre-trial incarceration, particularly when investigation is complete and trial is likely to take considerable time. The Court observed that detention pending trial should not assume punitive character. 44. Further, in Dataram Singh v. State of Uttar Pradesh (2018) 3 SCC 22, it was reiterated that grant of bail is a general rule and refusal an exception, and presumption of innocence continues until conviction. 45. Likewise, in P. Chidambaram v. Directorate of Enforcement (2020) 13 SCC 791, the Apex Court held that gravity of offence is an important factor, but it cannot be the sole ground to deny bail when the triple test — flight risk, possibility of tampering with evidence, and likelihood of influencing witnesses is satisfied. Thus, judicial approach must balance societal interest and personal liberty without pre-judging guilt. II. Completion of Investigation and Evidentiary Nature of Material 46. In the instant case, the investigation has advanced considerably, culminating in the filing of charge-sheets. The prosecution's narrative hinges predominantly on documentary, digital, and financial evidence, all of which has been meticulously gathered and safeguarded. No compelling necessity for the applicant's custodial interrogation is demonstrated at this juncture. Where the evidence is inherently documentary and securely held, prolonged detention serves no substantive investigative purpose.The Supreme Court in Sanjay Chandra (supra) held that once the prosecution relies on documentary 19 evidence already in the investigating agency's possession, extended detention ceases to be justified. III. Parity with Co-Accused 48. A substantial and weighty circumstance pressed into service by the applicant is that several co-accused, including those alleged to be the principal architects and beneficiaries of the purported conspiracy, have already been enlarged on bail by competent courts. It is not in dispute that in the present case multiple co-accused stand released on bail, both by this Hon’ble Court and by the Hon’ble Supreme Court. The principle of parity, therefore, squarely arises for consideration and cannot be lightly disregarded while adjudicating the present application. The co-accused Sanjay Mishra and Manish Mishra in MCRC No. 7093 of 2025 (order dated 23.09.2025); Vijay Bhatia in MCRC No. 5601 of 2025 (order dated 25.09.2025); Sunil Dutt in MCRC No. 188 of 2025 (order dated 12.03.2025); Abhishek Singh in MCRC No. 7790 of 2025 (order dated 11.11.2025); Chaitanya Baghel in MCRC No. 8224 of 2025; Atul Singh in MCRC No. 8857 of 2025 (order dated 13.01.2026); and Mukesh Manchanda in MCRC No. 8849 of 2025 (order dated 23.09.2025). 49. Further, the Apex Court has also enlarged several co-accused on bail, namely: Arvind Singh in SLP (Crl.) No. 2608 of 2025 (order dated 19.05.2025); Amit Singh in SLP (Crl.) No. 2545 of 2025 (order dated 19.05.2025); Deepak Duary in SLP (Crl.) No. 298 of 2025 (order dated 07.03.2025); Anurag Dwivedi in SLP (Crl.) No. 18386 of 20 2024 (order dated 07.03.2025); and Arunpati Tripathi in SLP (Crl.) No. 14466 of 2024 (order dated 07.03.2025). 50. Thus, persons alleged to have played major roles in the alleged scheme already stand enlarged on bail. In comparison, the role ascribed to the present applicant does not, at this stage, emerge as graver than those co-accused already enlarged on bail. Absent distinguishing circumstances warranting differential treatment, continued detention of the applicant would offend the settled principle of parity. Accordingly, parity with released co-accused constitutes a compelling circumstance tilting the balance in favour of enlargement, subject to safeguards ensuring fair trial and unhindered investigation. 51. It is not disputed that the applicant's name does not figure in the original FIR, surfacing solely during investigation. While this circumstance alone does not absolve liability, it retains material relevance in the bail calculus. No direct recovery stands attributed to the applicant. The prosecution's case pivots principally on digital communications and financial analysis—evidence documentary in character, secure against dissipation irrespective of custody. 52. In Niranjan Singh v. Prabhakar Rajaram Kharote, (1980) 2 SCC 559, the Apex Court cautioned that the bail stage must not degenerate into a mini-trial; courts are to assess only broad probabilities, eschewing detailed evidence scrutiny. 53. The applicant has endured incarceration for a considerable duration, a factor that acquires heightened significance in the bail 21 matrix under Section 439 CrPC. Given the multiplicity of accused, voluminous documentary evidence, and inherent complexity of unraveling financial transactions, the prospect of early trial conclusion appears remote and unrealistic. In Sanjay Chandra v. CBI, (2012) 1 SCC 40, the Apex Court has emphatically held that undertrial detention cannot metamorphose into punitive incarceration where trial prolongation is foreseeable; liberty cannot be sacrificed at the altar of investigatory or prosecutorial delays. 54. Under Article 21 of the Constitution, personal liberty stands enshrined as a fundamental right—pending trial incarceration must remain strictly commensurate with necessity, not morph into de facto punishment preceding conviction (Maneka Gandhi v. Union of India, (1978) 1 SCC 248; Hussainara Khatoon v. Home Secretary, State of Bihar, (1980) 1 SCC 81). 55. This Court, therefore, cannot countenance prolonged custody as a substitute for trial expedition; such an approach would erode the foundational principle that "bail is the rule, jail the exception" (State of Rajasthan v. Balchand, (1977) 4 SCC 308). Period Of Custody And likely Delay In Trial 56. The State voices apprehension that the applicant's enlargement may precipitate witness influence or investigatory interference. However, no specific overt act or tangible material has been adduced demonstrating the applicant's attempts to tamper while in custody. Such generalized apprehensions stand adequately neutralized through 22 imposition of stringent bail conditions—ensuring unwavering cooperation, prohibiting evidence interference, and mandating regular reporting. The Supreme Court in P. Chidambaram v. Directorate of Enforcement, (2020) 13 SCC 227, expressly recognized that meticulously tailored bail conditions can effectively safeguard prosecutorial interests without necessitating prolonged incarceration. Balancing Gravity and Liberty 57. Economic offences, though grave with widespread societal ramifications, cannot ipso facto eclipse the constitutional safeguard of personal liberty under Article 21. The Apex Court in Sanjay Chandra v. CBI, (2012) 1 SCC 40, authoritatively clarified that offence gravity alone cannot justify bail denial post substantial investigation completion and evidence securing—bail remains rule, not exception. Balancing allegation gravity against investigation culmination, co-accused parity, absent recovery, FIR omission, and protracted custody, the applicant's continued detention appears neither necessary nor proportionate at this stage. 58. In the absence of any material placed on record demonstrating that the role attributed to the present applicant is graver, exceptional, or distinguishable from that of co-accused persons who have already been enlarged on bail, selective continuation of their custody would amount to discriminatory treatment, contrary to settled principles governing grant of bail. Liberty cannot be curtailed on the basis of selective application of criminal process, particularly when persons alleged to be principal conspirators, facilitators, or beneficiaries of the 23 same transaction have already been granted liberty by competent courts. Judicial discretion must operate uniformly and cannot result in unequal treatment among similarly placed accused persons. 59. This Court is also mindful of the well-settled legal position that pre-trial incarceration is not punitive in nature and detention must be justified by compelling considerations such as likelihood of absconding, tampering with evidence, or influencing witnesses. No such exceptional or compelling circumstances have been demonstrated against the present applicants so as to warrant their continued confinement. 60. More importantly, investigation qua the present applicant stands completed and charge-sheet has already been filed before the trial Court. The prosecution case now substantially rests upon documentary and electronic evidence already secured and forming part of the record. Therefore, continued custody of the applicant does not appear necessary for purposes of investigation. 61. Without entering into the merits of the allegations and confining consideration strictly to the question of bail, this Court is of the considered opinion that no compelling or justifiable reason survives at this stage for further curtailment of the applicants’ personal liberty. The ends of justice would be sufficiently safeguarded by enlarging the applicant on bail, subject to appropriate conditions ensuring his presence during trial and preventing interference with the course of justice. 24 62. In view of the totality of circumstances elucidated hereinabove encompassing substantial investigation completion, predominantly documentary evidence, co-accused parity, FIR omission, absent recovery, protracted custody, trial delays, neutralized tampering apprehensions, and offence gravity appropriately balanced, this Court is of the considered opinion that the applicant merits enlargement on bail. The application is allowed. The applicant shall be released forthwith, subject to furnishing personal bond and surety to the satisfaction of the Trial Court, alongside strict compliance with the conditions delineated hereafter. 63. Accordingly, continued incarceration of the applicant at this stage is not warranted. It is directed that the Applicant shall be released on bail upon furnishing a personal bond in the sum of ₹1,00,000/- (Rupees One Lakh only) along with two local sureties of the like amount to the satisfaction of the learned Trial Court, subject to the following conditions: (i) he shall surrender his passport, if any, before the Trial Court; (b) the applicant must cooperate with the investigation and the trial proceedings; (c) he shall not directly or indirectly make any inducement, threat or promise to any person acquainted with the facts of the case; (d) he shall commit no offence whatsoever during the period he is on bail; and 25 (e) in case of change of residential address and/or 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. Sd/- (Arvind Kumar Verma) Judge SUGUNA DUBEY Digitally signed by SUGUNA DUBEY Date: 2026.03.03 17:32:05 +0530