Shaurya Sunil Kumar Singh v. Central Bureau of Investigation, 2026

The appellant was arrested in connection with a CBI investigation into an alleged large-scale cyber fraud.

The alleged fraud involved approximately ₹3.81 crore.

The FIR invoked provisions of the Bharatiya Nyaya Sanhita, Prevention of Corruption Act and Information Technology Act.

The investigating agency filed the charge sheet within the prescribed statutory period.

However, the accused contended that a copy of the charge sheet had not been supplied to him.

Relying upon this non-supply, he sought default bail under Section 187(3) BNSS.

The Bombay High Court rejected the application.

The High Court held that default bail arises from failure to file the charge sheet within the prescribed period, and not merely from failure to supply a copy of an already-filed charge sheet.

The accused challenged the High Court's decision before the Supreme Court.

The Supreme Court examined whether non-supply of the charge sheet could independently trigger the right to default bail.

The Supreme Court dismissed the appeal.

The Court upheld the Bombay High Court's decision rejecting default bail.

The Court held that non-supply of a copy of the charge sheet cannot by itself constitute a ground for default bail.

The relevant consideration under Section 187(3) BNSS is whether the investigating agency failed to file the charge sheet within the prescribed statutory period.

In the present case, the charge sheet had been filed within the applicable period.

Therefore, the statutory basis for claiming default bail was absent.

The Supreme Court found the reasoning of the courts below to be justified.

The appeal was consequently dismissed.

Core principle: The judgment distinguishes between the statutory requirement of filing the charge sheet within the prescribed period and the separate procedural obligation of supplying a copy to the accused.

Default bail: Default bail is a statutory safeguard against prolonged detention when the investigating agency fails to complete the investigation and file the required report within the prescribed period.

Trigger for the right: According to the Court, the relevant trigger is non-filing of the charge sheet within the statutory period, not merely non-supply of a copy after filing.

Filing versus supply: The judgment makes an important distinction between two different procedural events. Filing the charge sheet satisfies the condition relevant to default bail, whereas supplying a copy concerns the accused's access to the prosecution material.

No automatic default bail: The Court rejected the proposition that every procedural failure relating to the charge sheet automatically converts into a right to default bail.

Personal liberty: Although default bail is closely connected with the accused's personal liberty, the statutory conditions governing that right must still be satisfied.

Scope of Section 187(3): The Court interpreted the provision according to its statutory purpose: preventing detention beyond the permissible period where the investigation has not been completed and the required report has not been filed.

Practical significance: Investigating agencies must comply with procedural requirements concerning supply of documents, but failure to supply the charge sheet does not, by itself, confer a right to default bail where the charge sheet was timely filed.

Limited ruling: The judgment, based on the material provided, addresses only the default-bail consequence of non-supply. It does not mean that an accused has no legal entitlement to receive necessary prosecution documents at the appropriate stage.

Cyber-fraud context: The underlying case involved an alleged ₹3.81-crore cyber fraud, but the Supreme Court's ruling on the appeal concerned the specific question of default bail.