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Mukesh Rani vs. Narcotics Control Bureau

Bail Application · 2026:DHC:8876Decided 7 Oct 2026New Delhi Bench
BAIL APPLN. 2472/2026CNR: DLHC010277922026
Justice Mini Pushkarna

Background

Mukesh Rani was arrested at IGI Airport after arriving from Bangkok when officials recovered 986 grams of marijuana from her bag; a co-traveller was found carrying a similar quantity. She claimed she had been duped by the co-accused, who had promised her a job abroad and later persuaded her to carry a bag belonging to a stranger. She had been in custody for about four months, and the NCB argued the two women's combined recovery and coordinated travel pointed to a larger trafficking operation.

Decision Breakdown

The Court noted the investigation was complete, the chargesheet was filed, the co-accused had already been granted bail, and the combined quantity recovered (1.976 kg) still fell short of the "commercial quantity" threshold under the NDPS Act. With ten witnesses yet to be examined and no indication the trial would conclude quickly, the Court found continued detention unnecessary and granted regular bail on a personal bond of Rs. 50,000 with standard conditions.

Lesson Learnt

In NDPS cases, bail decisions turn heavily on whether the recovered quantity is "small," "intermediate," or "commercial," and even an intermediate-quantity case can qualify for bail once the investigation is complete and a co-accused in the same operation has already been released.

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