Authority: High Court of Orissa, Cuttack (Bench of Justice G. Satapathy)
Order Date: 14 August 2026
Case Overview
- The petitioner, Ramnarayan Bal, filed a bail application under Section 483 of the BNSS (2023) in BLAPL No.12135 of 2025.
- The application pertained to EOW, Bhubaneswar P.S. Case No. 17 of 2025 (C.T. Case No. 20 of 2025) pending before the Designated Court under the OPID Act, Cuttack.
- Allegations stem from FIR No. 17 dated 28‑10‑2025 lodged by Gobinda Chandra Nayak, accusing the petitioner of impersonating a State Bank of India (SBI) employee, misrepresenting the informant (representative of The World Ventures Ltd), and inducing the company to purchase six mortgaged bank properties at undervalue.
- The petitioner allegedly executed forged documents, used the SBI seal, and forged the signature of DGM (Zone‑3) Mr. Harihar Pattnaik, directing the company to transfer Rs 14,01,83,039/- to his personal account instead of a legitimate bank account.
- Investigation revealed the petitioner was a Sales Manager at “SBI Cap Securities” in Bhubaneswar from 2014‑2022 and was aware of bank mortgaged‑property sale procedures.
- A charge‑sheet was filed charging the petitioner under BNS Sections 318(4), 319(2), 338, 336(3), 340(2), 341(1) and 61(2).
- The petitioner is also implicated in five other criminal matters, disclosed via a comprehensive affidavit on 02‑07‑2026:
1. Bhadrak Town P.S. Case No. 264/2016 – IPC §§381, 406, 408, 420.
2. Baisinga P.S. Case No. 103/2019 – IPC §§408, 420.
3. Colliery P.S. Case No. 372/2024 – BNS §§318(4), 336(2), 336(3), 340(2), 3(5).
4. Bhadrak Town P.S. Case No. 567/2025 – BNS §§292, 296, 221, 3(5) with Fire Works & Loud Speaker Regulation Act and Motor Vehicles Act provisions.
5. Mancheswar P.S. Case No. 49/2026 – BNS §§316(2), 318(4), 336(2), 61(2).
- The petitioner’s bail plea rested on two grounds: alleged non‑compliance of Sec 47 of BNSS with Article 22(1) of the Constitution, and merits of the case.
- The Court examined the petitioner’s partial disclosure of his criminal antecedents, noting that only one case was mentioned in the original bail application, with the remaining four disclosed only after objection by the State on 19‑02‑2026.
- The Court cited Supreme Court precedents (Munnesh v. State of UP, Zeba Khan v. State of UP) emphasizing the duty of full and candid disclosure of material facts in bail applications.
- Detailed discussion on Sec 47 of BNSS and Article 22(1): the Court observed that while the petitioner argued non‑compliance, the arrest memo dated 29‑10‑2025 recorded the grounds of arrest, was signed by the petitioner, his wife, and the arresting officer, and the remand report showed the petitioner was informed of the allegations.
- The Court referenced recent Supreme Court judgments (Mihir Rajesh Shah v. State of Maharashtra, State of Meghalaya v. Sonam Raghuvanshi) clarifying that the requirement to communicate grounds of arrest in writing applies prospectively from the date of those judgments; the petitioner’s arrest on 29‑10‑2025 preceded those decisions.
- The petitioner’s plea of non‑compliance was deemed “inadequate compliance” rather than total non‑compliance, and no prejudice was demonstrated.
- On merits, the Court noted the seriousness of the alleged fraud, the existence of 56 charge‑sheeted witnesses, the petitioner’s prior absconding order (NBWA) in the Baisinga case, and the fact that the petitioner had not disclosed his antecedents fully, all constituting adverse factors against bail.
Final Outcome
- The High Court of Orissa dismissed the bail application, holding that the petitioner is not entitled to bail either on technical grounds of non‑compliance or on merits. The BLAPL stands disposed of, and a copy of the order is to be transmitted to the learned Court in seisin.
Topics: Legal Bail Decision, Financial Fraud, Criminal Procedure