Deepak Kumar Pradhan @ Dulu S/O Shri Madhav Pradhan Vs State of Rajasthan

[2026:RJ-JP:687]

HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR

S.B. Criminal Miscellaneous Bail Application No. 12631/2025

Deepak Kumar Pradhan @ Dulu S/o Shri Madhav Pradhan, Aged About 55 Years, R/o Kanbagri Taki Sahi, Police Station Jiudaigiri, District Kandhmal, Orisa. (At Present In Sub Jail, Bayana, Bharatpur).

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----Petitioner

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Versus

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State Of Rajasthan, Through Pp

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----Respondent

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Connected With

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S.B. Criminal Miscellaneous Bail Application No. 12632/2025 Pramod Saini @ Dhaularam S/o Shri Krishan Kumar, Aged About 23 Years, R/o Barabas, Police Station Kotputli, District Kotputli Behrod (Rajasthan) (Accused Petitioner Is In J/c At Sub Jail, Bayana, Bharatpur).

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----Petitioner

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Versus

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State Of Rajasthan, Through Pp

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----Respondent

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For Petitioner(s)	: Mr. V.D. Agrihotri Mr. Chandra Mohan Sharma Mr. Hoshiyar Singh Arya Mr. AnoopAgarwal
For Respondent(s)	: Mr. Manvendra Singh Shekhawat, PP Mr. Vivek Sharma,PP

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HON'BLE MR. JUSTICE PRAMIL KUMAR MATHUR

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Order

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07/01/2026

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The petitioners have preferred these bail applications under Section 483 of BNSS in FIR No.43/2025 registered at Police Station Gahnoli Mod, District Bharatpur for the offence under Sections 8/20 of NDPS Act, 1985.

[2026:RJ-JP:687]

[CRLMB-12631/2025]

(2 of 4)

Since both these bail applications arise out of a common FIR, therefore, they are being decided by this common order.

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The prosecution case is that 600 Kgs of Ganja was seized from the conscious possession of co-accused Suwa Lal and Nitesh Singh. The present petitioners are alleged to be prospective seller/buyers and their role has been assigned on the basis of call detail records (CDRs) and financial transactions showing active communication and co-ordination with the other co-accused.

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Heard learned counsel for the petitioners, learned Public Prosecutor and perused the material available on record. 5. Learned counsel for the petitioners submits that the petitioners have falsely been implicated. It is contended that no contraband has been recovered from their conscious possession, nor were they present at the spot. It is argued that the case rests solely on call detail records and financial transactions, and therefore, the bar under Section 37 of the NDPS Act is not attracted. It is further submitted that mere telephonic conversations and financial transactions do not establish conspiracy. It is also contended that the mandatory provisions of Section 50 of the NDPS Act were not complied with. Learned counsel further submits that petitioner Deepak is in custody since 22.03.2025 and petitioner Pramod since 11.06.2025. The charge-sheet has already been filed, the petitioners have no criminal antecedents, and the trial is likely to take considerable time; therefore, benefit of bail deserves to be granted.

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In support of his submissions, learned counsel has relied on the following judicial pronouncements:

[2026:RJ-JP:687]

[CRLMB-12631/2025]

(3 of 4)

1. Ratan Lal Vs. State of Rajasthan, 2024(1) WLC 580 (Raj.)

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2. Bhomaram Vs. State of Rajasthan, 2024(1) RLW 877 (Raj.)

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Per contra, learned Public Prosecutor has vehemently opposed the bail applications. It is submitted that the contraband seized is of commercial quantity, and therefore, the rigors of Section 37 of the NDPS Act are clearly attracted. The CDRs and financial transactions reflect frequent communication and coordination between the petitioners and the co-accused, which prima facie establishes their active role in the illicit trafficking of contraband. It is further submitted that there are reasonable grounds to believe the involvement of the petitioners in the offence and that the possibility of tampering with evidence cannot be ruled out; hence, the bail applications deserve to be rejected.

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Having considered the rival submissions and the material available on record, and upon careful deliberation of all the facts and circumstances of the case, this Court finds that the contraband recovered is of huge commercial quantity, attracting the statutory bar under Section 37 of the NDPS Act, and the call detail records showing continuous and frequent communication between the petitioners and the co-accused surrounding the date and time of seizure. The material placed on record indicates financial linkage and co-ordination, forming prima facie conspiracy under Section 29 of the NDPS Act. At this stage, the Court is not required to meticulously examine the evidence, but only to determine whether reasonable grounds exist to believe the guilt of the petitioners.

(4 of 4)

[2026:RJ-JP:687]

[CRLMB-12631/2025]

Hence, this Court is not satisfied that the petitioners have been able to overcome the twin conditions mandated under Section 37 of the NDPS Act. The quantity seized is huge, the role attributed to the petitioners is substantial, and the likelihood of their indulging in similar activities cannot be ruled out.

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As both the judicial pronouncements relied upon by learned counsel for the petitioners are based on disclosure statements of co-accused which is not the case of prosecution here, hence the same are of no avail.

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Accordingly, without expressing any opinion on the merits or demerits of the case, the Court is not inclined to grant the benefit of bail.

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Consequently, the bail applications under Section 483 BNSS are dismissed.

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(PRAMIL KUMAR MATHUR),J

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bmg/61-62

Deepak Kumar Pradhan @ Dulu S/O Shri Madhav Pradhan v. State of Rajasthan

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Deepak Kumar Pradhan @ Dulu S/O Shri Madhav Pradhan v. State of Rajasthan

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