Shailesh Katre Vs State of Chhattisgarh — Chhattisgarh HC (2026) — LawSathi Research

Shailesh Katre Vs State of Chhattisgarh — Chhattisgarh HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Applicant directed to be released on regular bail on furnishing a personal bond in the sum of Rs.25,000/- with one surety in the like sum to the satisfaction of the trial Court, for his appearance before the said Court as and when directed.

Issue for consideration

Whether the applicant Shailesh Katre should be enlarged on regular bail in Crime No.466/2025 (Police Station Khairagarh) for the offences under Sections 296, 115(2), 351(3), 3(5), 103(1) of BNS 2023.

Court's answer

Having considered the submissions of learned counsel for the parties and the overall facts of the case — especially that either the FIR or the 161 CrPC statement of the deceased/complainant does not mention the name of the applicant, and looking to his custody period — the Court was inclined to release the applicant on regular bail, and accordingly allowed the bail application directing release on a personal bond of Rs.25,000/- with one surety in the like sum.

Detailed headnote1 paragraphs

Chhattisgarh High Court at Bilaspur (Hon'ble Shri Justice Sanjay Kumar Jaiswal) allowed the first regular-bail application of Shailesh Katre filed under Section 483 of the Bhartiya Nagarik Suraksha Sanhita, 2023 in Crime No.466/2025 of Police Station Khairagarh, registered for offences under Sections 296, 115(2), 351(3), 3(5), 103(1) of BNS 2023. The prosecution alleged that on 07.10.2025 three unknown persons tried to snatch the sound box and wiring of a Saraswati idol Pandal and assaulted the Pandal staff, including complainant/deceased Mohanlal, with an iron rod; the complainant lodged the FIR but died on 25.10.2025, 18 days after the incident. Decisive factors for grant of bail: neither the FIR nor the deceased's s.161 CrPC statement mentioned the applicant's name, no seizure was made from him, no Test Identification Parade was conducted, and he had been in custody since 26.10.2025 with the charge sheet filed and 19 prosecution witnesses listed. The applicant was ordered released on a personal bond of Rs.25,000/- with one surety in the like sum to the satisfaction of the trial Court.

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Digitally signed by ALLENA ALLENA ANNAJEE ANNAJEE RAO RAO Date: 2026.02.20 11:39:11 +0530

2026:CGHC:8885

NAFR

HIGH COURT OF CHHATTISGARH AT BILASPUR

MCRC No. 1360 of 2026

Shailesh Katre S/o Shivlal Katre Aged About 32 Years R/o Changorabhata, Raipur District- Raipur (C.G.) ... Applicant

versus

State of Chhattisgarh through- Station House Officer, Police StationKhairagarh, District- Khairagarh-Chhuikhadan-Gandai (C.G.) ...

Respondent

For the Applicant : Mr. A. D. Kuldeep & Ms. Khushbu Sahu Advocates on behalf of Mr. C. R. Sahu, Advocate. For the State : Mr. Sumit Singh, Deputy Advocate General

(Hon’ble Shri Justice Sanjay Kumar Jaiswal)

Order on Board

19.02.2026

1. This is first bail application filed under Section 483 of the Bhartiya Nagarik Suraksha Sanhita, 2023 for grant of regular bail to the applicant in Crime No.466/2025 registered at Police Station Khairagarh, Distt. Khairagarh-Chhuikhadan (CG) for the offences under Sections 296, 115(2), 351(3), 3(5), 103(1) of BNS 2023.

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2. The prosecution story, in brief, is that on 07.10.2025 the complainant/deceased Mohanlal has lodged the report stating that in their village the idol of goddess Saraswati has been installed in a Pandal and he alongwith one Ramsukh Banjare were sleeping in the night as Pandal Staff. At that time, 3 unknown persons opened the Amply box with the intention to snatch away the sound box and wire. The complainant and his colleague got up and resisted the said act, on which, the accused persons abused them in filthy language and assaulted them with iron rod, due to which, they sustained injuries. On raising alarm, the locals of neighborhood came there and seeing them, the accused ran away.

3. Learned counsel for the applicant submits that the incident is said to have taken place on 07.10.2025 and the complainant had died much after on 25.10.2025 i.e., after 18 days of the incident and it cannot be said that the death of complainant was caused due to the said assault. He further submits that neither the FIR nor the statement of deceased/ complainant recorded u/s 161 CrPC does not mention the name of the applicant and further no seizure was made from him. He next submits that the Test Identification Parade was also not conducted. He submits that applicant is in jail since 26.10.2025; the charge sheet has been filed and there are total 19 prosecution witnesses in this case and there is no immediate possibility of disposal of case, therefore, he may be enlarged on bail. 4. Per contra, learned State Counsel opposes the bail application and submits that the FIR was filed by the deceased himself and his 161 CrPC statement was recorded.

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5. Having considered the submissions made by learned counsel for the parties and the over-all facts situation of the case especially the fact that either the FIR or 161 CrPC statement of deceased/complainant does not mention the name of applicant and further looking to his custody period, I am inclined to release the applicant on regular bail.

6. Accordingly, this bail application is allowed and the applicant is directed to be released on bail on his furnishing a personal bond in sum of Rs.25,000/- with one surety in the like sum to the satisfaction of the trial Court for his appearance before the said Court as and

when directed in that behalf.

Cc as per rules.

Sd/(Sanjay Kumar Jaiswal) Judge

Rao