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High Court of Gujarat

RINABEN W/O SUNILBHAI ASHOKBHAI PARMARversusSTATE OF GUJARAT

Disposal
39-RULE DISCHARGED/DISMISSED @ FH

Holding

The application for regular bail was dismissed as the accused suppressed material facts about her extensive prior antecedents.

Summary

The applicant, Rinaben, filed a regular bail application under Section 483 of the BNSS after a chargesheet was filed for offences under Sections 108, 352, 115(2) and 54 of the BNS and Sections 40 and 42 of the Gujarat Money Lenders Act. The applicant claimed to have no prior criminal record, but the respondent highlighted that the Gujarat Police portal shows more than 450 past antecedents. The court noted that the applicant, although a woman, had suppressed material facts regarding her criminal history. Relying on Supreme Court precedents (Munnesh v. State of Uttar Pradesh and Firoj @ Farhu v. State of Rajasthan), the court dismissed the bail application without examining the merits. Consequently, the applicant remains in custody.

Issues considered

  • Whether regular bail can be granted after a chargesheet when the accused has undisclosed prior criminal antecedents
  • Whether suppression of material facts regarding past antecedents justifies denial of bail

Subjects

regular bailchargesheetsuppression of material factsprior criminal antecedentsbail jurisprudencecriminal procedure

Judgment

       R/CR.MA/18836/2026                                                          ORDER DATED: 17/08/2026




               IN THE HIGH COURT OF GUJARAT AT AHMEDABAD

       R/CRIMINAL MISC.APPLICATION (FOR SUCCESSIVE REGULAR BAIL - AFTER
                        CHARGESHEET) NO. 18836 of 2026
==========================================================
           RINABEN W/O SUNILBHAI ASHOKBHAI PARMAR
                            Versus
                      STATE OF GUJARAT
==========================================================
Appearance:
MS SHALINI S MAIR(2681) for the Applicant(s) No. 1
MR KRUTIK PARIKH, APP for the Respondent(s) No. 1
==========================================================
  CORAM:HONOURABLE MR. JUSTICE HASMUKH D. SUTHAR
                      Date : 17/08/2026
                           ORDER
          Registry to accept vakalatnama of learned advocate Ms. Shefali U.
Tamaichi, who has instructions to appear for the original complainant.
          Present application is 7led under Section 483 of the BNSS seeking
regular bail in connection with FIR being CR No.11198006261046 of 2026
registered with Ghogha Road Police Station, District Bhavnagar for the
o>ences punishable under Sections 108, 352, 115(2) and 54 of the BNS and
sections 40 and 42 of the Gujarat Money Lenders Act.
          Perusing the averments made in the application, it is mentioned that
applicant is not having any past antecedent however, the learned APP has
pointed out from the portal of Gujarat Police that the applicant is having
more than 450 past antecedents.
          In view of above, though the applicant is a lady accused but since the
applicant has suppressed material facts pertaining to her past antecedents,
in view of the decision of the Hon’ble Supreme Court in the case of
Munnesh vs. State of Uttar Pradesh [2025 LiveLaw (SC) 389] as well as
Firoj @ Farhu vs. State of Rajasthan [SLP Crl. No. 14532 of 2025], without
going into merits, present application stands dismissed.



                                                                          (HASMUKH D. SUTHAR, J.)
Ajay
       Original copy of this order has been signed by the Hon'ble Judge.
       Digitally signed by: AJAY CHANDRAN MENON(HC00939), PRINCIPAL PRIVATE SECRETARY, at High Court of Gujarat on 17/08/2026 14:20:32



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