The Supreme Court of India has allowed a criminal appeal and granted regular bail to an individual accused under the Narcotic Drugs and Psychotropic Substances Act, 1985 (NDPS Act), emphasizing that a case for bail was made out given the facts on record, including nearly two years of incarceration and a slow-moving trial.
The Bench comprising Justice B.V. Nagarathna and Justice Ujjal Bhuyan set aside the order of the High Court of Chhattisgarh which had previously rejected the appellant’s bail application.
Background of the Case
The appellant, Satyjeet Bhoi, was booked in connection with FIR No. 29/2024 dated March 25, 2024, registered at Police Station Singhoda, District Mahasamund. The charges involved offences punishable under Section 20(B) of the NDPS Act following the recovery of 150 Kilograms of Ganja from a truck.
Bhoi had been in custody since the date of the FIR. After the High Court of Chhattisgarh at Bilaspur rejected his regular bail application in MCRC No. 5275 of 2025 on July 14, 2025, he moved the Supreme Court via a Special Leave Petition.
Arguments of the Parties
Appearing for the appellant, Dr. Anindita Pujari, Senior Advocate, assisted by advocates Mr. Shaileshwar Yadav, Mr. Rohit Kumar-i (AOR), Ms. Radhika Mohapatra, and Mr. Shailendra Singh, submitted that the allegations against Bhoi were “untrue.” It was argued that the appellant was merely a passenger in the truck that was detained. The counsel contended:
“Merely because the appellant was a passenger in the truck which was detained and the contraband (150 Kilograms of Ganja was recovered), the same cannot be linked with the appellant herein.”
The defense further highlighted that no material had been brought on record to establish a nexus between the appellant and the contraband. It was also noted that the trial had not progressed substantially, with fifteen witnesses still to be examined, making further delay inevitable.
Conversely, Mr. Vikrant Singh Bais, Deputy Advocate General for the State of Chhattisgarh, appearing with advocates Mr. Vinayak Sharma and Mr. Ravinder Kumar Yadav (AOR), opposed the bail. The State referred to a counter-affidavit, arguing that the High Court was justified in its refusal because the co-accused (the driver of the truck) remained in jail. The State contended that granting bail would “result in frustration of the trial.”
Court’s Analysis and Decision
After perusing the material on record and hearing both sides, the Supreme Court observed that the appellant had been in jail for almost two years. The Court found merit in the plea for relief, stating:
“Considering the facts on record, in our view, the case for bail is made out.”
The Court allowed the appeal and directed that the appellant be produced before the concerned Trial Court as early as possible for release on bail. The release is subject to conditions deemed appropriate by the Trial Court to ensure his presence during proceedings.
Mandates for the Appellant
The Bench imposed strict conditions on the grant of liberty, directing that:
- The appellant must extend complete cooperation in the ensuing trial.
- The appellant shall not misuse his liberty, influence witnesses, or tamper with material on record.
- The appellant must ensure his presence before the Special Court/Trial Court on every date of hearing, unless a valid cause for exemption is provided.
The Court warned that “any infraction of the conditions may entail cancellation of bail.”
Case Details:
- Case Title: Satyjeet Bhoi vs. State of Chhattisgarh & Another
- Case Number: Criminal Appeal No(s). [Arising out of SLP(Crl.) No. 2401/2026]
- Coram: Justice B.V. Nagarathna and Justice Ujjal Bhuyan
- Date of Order: March 16, 2026
