Prem Shankar Sahu Vs State of Chhattisgarh — Murder and Culpable Homicide | Chhattisgarh HC (2026)

Prem Shankar Sahu Vs State of Chhattisgarh — Murder and Culpable Homicide | Chhattisgarh HC (2026)

What the court decided

AI extract

Outcome

Dismissed

Issue for consideration

Whether the applicant, arraigned in Crime No. 456/2024 of P.S. Khamhardih, District Raipur for offences under Sections 103(1) and 315 of BNS, should be enlarged on regular bail under Section 483 of the Bhartiya Nagarik Suraksha Sanhita, 2023.

Court's answer

Having considered the submissions of learned counsel for the parties, the overall facts and circumstances and the nature of allegations made against the applicant, the Court was not inclined to release the applicant on regular bail and rejected the first bail application.

Ratio / Principle

Looking to the long custody period of the applicant, the trial Court was directed to expedite the trial as early as possible, preferably within a period of 5 months from the date of receipt of a copy of the order.

Key takeaways

The Registry was directed to send a copy of the order to the trial Court for necessary information.ratio¶21

Detailed headnote1 paragraphs

Regular bail rejected — Prem Shankar Sahu (MCRC No. 3305 of 2026, High Court of Chhattisgarh at Bilaspur, Hon'ble Shri Justice Sanjay Kumar Jaiswal, order dated 16.04.2026). First bail application under Section 483 of the Bhartiya Nagarik Suraksha Sanhita, 2023 by the applicant, aged about 30 years, accused in Crime No. 456/2024 of P.S. Khamhardih, District Raipur for offences under Sections 103(1) and 315 of BNS, arising from a quarrel at a construction site on 29.10.2024 in which he allegedly assaulted the deceased, who succumbed to the injuries. Counsel for the applicant contended there was no eyewitness, the FIR was lodged against an unknown person, the FSL report did not disclose the group of human blood found on the wooden plank, the applicant had been in custody since 01.11.2024, and only 12 of 21 witnesses had been examined. The State opposed, relying on the last-seen statement of P.W.1 Anil and the seizure of a motorcycle and a mobile phone from the applicant. The Court, not inclined to release the applicant on regular bail in view of the nature of allegations, rejected the application; considering the long custody, it directed the trial Court to expedite the trial preferably within five months, and directed the Registry to send a copy of the order to the trial Court.

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	Digitally signed by ALLENA
ALLENA	ANNAJEE
ANNAJEE	RAO
RAO	Date: 2026.04.20
	11:44:56 +0530

2026:CGHC:17506

HIGH COURT OF CHHATTISGARH AT BILASPUR

MCRC No. 3305 of 2026

Prem Shankar Sahu S/o Ganga Sagar Sahu Aged About 30 Years R/o Gram Potiya, P.S. Bheemkhoj, District- Mahasamund Currently R/o Raheja Nirvana Kachna P.S. Khamhardih, District- Raipur (C.G.) ... Applicant

versus

State of Chhattisgarh through Station House Officer (S.H.O.) P.S. Khamhardih District- Raipur (C.G.) ... Respondent

For the applicant : Ms. Shalvin Sharma and Mr. Ravi Kumar Kashyap, Advocates For the State : Ms. Sunita Manikpuri, Govt. Advocate

(Hon’ble Shri Justice Sanjay Kumar Jaiswal)

Order on Board

16.04.2026

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. 456/2024 registered at Police Station Khamhardih, District Raipur (CG) for the offences under Sections 103(1), 315 of BNS.

2 As per the prosecution case, on 29.10.2024 a quarrel took place between the applicant and deceased at a construction site and in a spur of moment, the applicant hit the deceased and caused him injuries, due to such assault, the deceased succumbed to the injuries.

3. Learned counsel for the applicant submits that there is no eyewitness to the incident; the FIR was lodged against unknown person and

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the present applicant has been falsely implicated in this case. He submits that as per the prosecution case, human blood was present on the wooden plank but it is not mentioned in the FSL report as to which group of human blood was found. He submits that the applicant is in jail since 01.11.2024; till date out of total 21 witnesses, only 12 have been examined and there is no immediate possibility of disposal of the case, therefore, looking to the long custody period, the applicant may be enlarged on bail.

4. Per contra, learned State Counsel opposes the bail application and submits that P.W.1 Anil has stated that the deceased was last seen with the applicant. The motorcycle and a mobile phone have been seized from the applicant.

5. Having considered the submissions made by learned counsel for the parties; the over all facts and circumstances of the case and looking to the nature of allegations made against the applicant, I am not inclined to release the applicant on regular bail. Accordingly, the bail application is rejected.

6. However, looking to the long custody period of the applicant, the trial Court is directed to expedite the trial as early as possible preferably within a period of 5 months from the date of receipt of copy of this order.

7. Registry shall send a copy of this order to the trial Court for necessary information.

Sd/(Sanjay Kumar Jaiswal) Judge

Rao