Satish Chandra vs The State Of Madhya Pradesh on 20 March, 2026

Author: Milind Ramesh Phadke

Bench: Milind Ramesh Phadke

NEUTRAL CITATION NO. 2026:MPHC-GWL:9810

1 MCRC-12465-2026
IN THE HIGH COURT OF MADHYA PRADESH
AT GWALIOR
BEFORE
HON'BLE SHRI JUSTICE MILIND RAMESH PHADKE
ON THE 20th OF MARCH, 2026
MISC. CRIMINAL CASE No. 12465 of 2026
SATISH CHANDRA
Versus
THE STATE OF MADHYA PRADESH
Appearance:
Ms. Ayushi Kushwah - Advocate for the applicant.
Shri Samar Ghuraiya - Public Proseuctor for the State.
WITH
MISC. CRIMINAL CASE No. 12332 of 2026
PRAVEEN SHIVAJI BHAMRE
Versus
THE STATE OF MADHYA PRADESH
Appearance:
Shri Girraj Soni - Advocate for the applicant.
Shri Samar Ghuraiya - Public Proseuctor for the State.

ORDER

The present applications under Section 483 of BNSS filed by the applicants No.1 and 2, namely, Satish Chandra and Praveen Shivaji Bharme for grant of their regular bail. They have been arrested on 12.01.2026 by Police Station City Kotwali, District Bhind in connection with Crime No.24/2026 registered at Police Station Dehat District Bhind

NEUTRAL CITATION NO. 2026:MPHC-GWL:9810

2 MCRC-12465-2026 for offences under Sections 318(4), 3(5), 338, 336(3), 340(2) and 61 of IPC.

As per the case of the prosecution, a news report published in Dainik Bhaskar on 09.01.2026 indicated that certain individuals Ajit Singh, Gaurav Singh, Hemant Rajendra Devre, Rahul Daulat, Javed Anwar, and Mohammad Rashid had obtained arms licenses through fraudulent means. Upon verification of the arms license records, both in the official register and on the NDAL-ALIS online portal, no valid records were found in their names. The news report further indicated that fake arms licenses were being prepared by unknown persons or gangs operating in the Gwalior-Chambal region of Madhya Pradesh, as well as

in Uttar Pradesh and Jammu. It was alleged that the accused persons were charging approximately Rs.3 lakh for preparing such fake licenses by collecting Aadhaar cards, PAN cards, and photographs under the pretext of an online process. Although the licenses bore a QR code and mentioned the Office of the District Magistrate, Bhind, they were not found registered on the official portal. Based on a written complaint submitted by the Assistant Grade-3 of the Arms Branch, Collectorate Bhind, Crime No.24/2026 was registered at Police Station Dehat under Sections 318(4) and 3(5) of the BNS against the named persons and others. During investigation, Sections 338, 336(3), 340(2), and 61 of the BNS were also added. As per the memorandum statement of accused Satish Chandra (applicant No.1), he, in conspiracy with co-accused

NEUTRAL CITATION NO. 2026:MPHC-GWL:9810

3 MCRC-12465-2026 Radhacharan and Atal Kushwah, facilitated the preparation of fake arms licenses and procurement of pistols for other co-accused persons, namely Rohit, Praveen(applicant No.2), Bharat, Hemant, and Rahul Patil. It was further alleged that Aadhaar cards of these individuals were digitally altered to reflect addresses in Bhind district. The applicant/accused used to receive an amount ranging from Rs.50,000 to ₹1,00,000 per license.

Learned counsel for the applicants submits that the applicants are innocent persons and have been falsely implicated in the present case. It is contended that the entire prosecution story is based upon a newspaper report and subsequent assumptions drawn during investigation, and there is no direct or cogent evidence connecting the present applicants with the alleged offence. It is further submitted that the memorandum statement of the co-accused, as relied upon by the prosecution, is not admissible in evidence except to the limited extent permissible under law, and no recovery of any incriminating article has been made from the possession of the present applicants pursuant to such statement. It is further submitted that the applicants have not prepared any fake arms licenses nor have they been involved in any such illegal activity as alleged by the prosecution. It is further submitted that merely because certain documents or alleged slips have been shown to be seized does not establish the involvement of the applicants in the commission of the offence, especially in the absence of any independent corroboration. It is

also submitted that there is no evidence to show that any monetary

NEUTRAL CITATION NO. 2026:MPHC-GWL:9810

4 MCRC-12465-2026 transaction, as alleged by the prosecution, ever took place between the applicants and any of the co-accused persons. It is further contended that the applicants have been in custody since 12.01.2026 and the investigation is still ongoing, and therefore, their further custodial interrogation is not required. There is no likelihood of their absconding or tampering with prosecution evidence. Learned counsel further submits that similarly placed co-accused Rohit Baliram Chandole has already been granted bail by this Court vide order dated 10th March, 2026 passed in M.Cr.C. No. 10414 of 2026. It is also argued that the prosecution has already seized the relevant documents and material, and therefore, there is no possibility of any further interference by the applicants. The applicants are ready and willing to abide by any condition that may be imposed by this Court while granting bail. On these grounds, it is prayed that the applicants be enlarged on regular bail.

Per contra, learned Public Prosecutor for respondent/State as well as counsel for the complainant had vehemently opposed the bail applications and had prayed for their rejection by contending that on the basis of the allegations and the material available on record, no case for grant of bail is made out.

Taking into account the overall facts and circumstances of the case, the arguments advanced by learned counsel for the parties coupled with the fact that the trial is not likely to conclude in near future and prolonged pre- trial detention being an anathema to the concept of

NEUTRAL CITATION NO. 2026:MPHC-GWL:9810

5 MCRC-12465-2026 liberty, this Court is inclined to extend the benefit of bail to the applicants. Accordingly, without expressing any opinion on merits of the case, the applications are allowed and it is directed that the applicants be released on bail upon each of them furnishing a personal bond in the sum o f Rs.50,000/- (Rupees Fifty Thousand only) with one local solvent surety of the like amount to the satisfaction of the trial Court/committal Court for their appearance on the dates given by the concerned Court, subject to compliance of the following conditions by the applicant:-

i. The applicants will comply with all the terms and conditions of the bond executed by them;

ii. The applicants will cooperate in the investigation/trial, as the case may be;

iii. The applicants will not indulge themselves in extending inducement, threat or promise to any person acquainted with the facts of the case so as to dissuade him from disclosing such facts to the Court or to the Police Officer, as the case may be;

iv. The applicants shall not commit any other offence during pendency of the trial, failing which this bail order shall stand cancelled automatically, without further reference to the Bench;