Ravi Goyal vs. The State Of Madhya Pradesh
Held
The Court allowed the bail application. The primary reasoning was that the charge sheet had been filed and a co-accused was already in jail, which addressed the concerns raised in the previous bail application regarding potential interference with the investigation. The Court found merit in the applicant's contentions. The ratio decidendi is that once the investigation is complete with the filing of the charge sheet and key co-accused are in custody, continued detention of the applicant may not be necessary, even in cases involving significant financial implications under the GST Act. The operative direction was to release the applicant on bail upon furnishing a personal bond of Rs. 50,000/- with one solvent surety of like amount, subject to his regular appearance before the trial court and adherence to conditions under Section 437(3) of the Criminal Procedure Code, 1973. The Court explicitly stated it was not commenting on the merits of the case.
Facts
This is the second bail application filed by Ravi Goyal (the applicant) under Section 483 of BNSS, 2023 / 439 of Criminal Procedure Code, 1973. The applicant is implicated in Crime No.748/2023 registered at Police Station DGGI, Bhopal Zone, for offences under Section 132(1)(B) & (C) read with Section 69(1) of the GST Act, 2017. The applicant has been in jail since May 9, 2025. His first bail application was dismissed on merits, with liberty to renew the prayer after charge sheet filing or arrest of co-accused. The charge sheet was filed on July 4, 2025, and a co-accused, Rajesh Goyal, is in custody. The disputed amount is Rs. 16.4 Lakhs.
Key Issues
1. Whether the applicant is entitled to bail under Section 439 of the Criminal Procedure Code, 1973, considering the filing of the charge sheet and the arrest of a co-accused, despite the alleged huge defalcation under the GST Act, 2017? Contentions: Petitioner/Applicant (Ravi Goyal): Submitted that the charge sheet has been filed and a co-accused is in custody, therefore, further custody of the applicant is not necessary. Argued that at most, a penalty would be imposed in a departmental inquiry. Revenue/State (The State of Madhya Pradesh): Opposed the prayer, citing the huge defalcation of Rs. 16.4 Lakhs and suggesting the applicant be directed to deposit some amount as a pre-condition for bail.
Sections Cited
Section 132(1)(B), Section 132(1)(C), Section 69(1), Section 483, Section 439, Section 437(3)
AI-generated summary — verify with the full judgment below
Cause title — parties, addresses and appearances
ORDER
They are heard. Perused the case diary / challan papers.
This is the second bail application filed by the applicant under Section 483 of BNSS, 2023 / 439 of Criminal Procedure Code, 1973, as he / she is implicated in connection with Crime No.748/2023 registered at Police Station / DGGI, Bhopal Zone, Bhopal (MP) for offence punishable under Section 132(1)(B) & (C) r/w Section 69(1) of GST ACt, 2017. The applicant is lodged in jail since 09/05/2025. 3. His first bail application M.Cr.C. No.22828/2025 was dismissed by this Court on merits, however, with a further liberty to the applicant to renew his prayer after the charge sheet is fled or after the other co-accused persons are arrested as it was contended by the counsel for the respondent, at that time, that if the applicant
The judgment continues below.
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