Patna High Court
Satendra Yadav @ Sandip MishraversusThe State of Bihar
- Decided
- Disposal
- DISMISSED
- Bench
- SANDEEP KUMAR
Holding
Regular bail was denied to the petitioner.
Summary
Satendra Yadav (also known as Sandip Mishra) was arrested in connection with a case involving the abduction of a victim, the transmission of the victim's photograph to his family, and extortion of Rs. 12,000 via UPI. He is charged under Sections 137(2), 352 and 3(5) of the Bharatiya Nyaya Sanhita, 2023 and has given a self‑inculpatory statement. The petitioner, who has six prior criminal antecedents (all on bail), applied for regular bail after being in custody since 03‑05‑2025. The State opposed the bail, emphasizing the seriousness of the offences and the petitioner’s involvement revealed during investigation. The Patna High Court, considering the nature of the accusations and the petitioner’s criminal record, declined to grant regular bail and dismissed the application. The court clarified that its observations were prima facie and limited to the bail application, not to be taken as a judgment on the merits of the trial.
Issues considered
- Whether regular bail should be granted to the petitioner given the seriousness of the offences under the Bharatiya Nyaya Sanhita and his criminal antecedents.
- Whether the self‑inculpatory statement and investigation findings justify denial of bail.
Legislation cited
- Bharatiya Nyaya Sanhita, 2023 — s. 137(2), 3(5), 352
Subjects
- regular bail
- criminal antecedents
- extortion
- abduction
- Bharatiya Nyaya Sanhita
- Patna High Court
- criminal procedure
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.69366 of 2025
Arising Out of PS. Case No.-95 Year-2024 Thana- Narhiya District- Madhubani
======================================================
Satendra Yadav @ Sandip Mishra Son of Iski Lal Yadav R/o Village -
Dhabahi, P.S.- Laukahi, District - Madhubani
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr. Subodh Jha, Advocate
Mr. Hriday Narayan Harshit, Advocate
For the Opposite Party/s : Mr. Md. Mushtaque Alam, APP
======================================================
CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
ORAL ORDER
5 05-05-2026 Heard learned counsel for the petitioner and learned
APP for the State.
2. The petitioner seeks regular bail in connection with
Narhaiya P.S. Case No. 95 of 2024, corresponding to G.R. No.
2031 of 2024, registered for the offence under Sections 137(2),
352 and 3(5) of the Bharatiya Nyaya Sanhita, 2023.
3. The victim was abducted by unknown criminals
and thereafter they sent his photograph to the family of the
victim and they withdrew Rs. 12,000/- from his mobile through
UPI. The petitioner (Satyendra Yadav) has given his self-
inculpatory statement before the Police that he is also involved
in the crime. Petitioner has six criminal antecedents and in all
cases he is on bail.
Patna High Court CR. MISC. No.69366 of 2025(5) dt.05-05-2026
2/2
4. Learned counsel for the petitioner submits that
petitioner is innocent and has not committed any offence.
Petitioner is in custody since 03.05.2025.
5. Learned A.P.P. for the State has vehemently
opposed the prayer for bail and has submitted that the name of
the petitioner has transpired during the investigation. The
extortion was done after taking the photograph of the victim and
sending it to his family members.
6. Considering the nature of the accusation and the
criminal antecedents of the petitioner, this Court is not inclined
to grant regular bail to the petitioner.
7. Accordingly, this application stands dismissed.
8. It is made clear that any observation made herein is
prima facie in nature and limited solely for the purpose of
adjudication of the present bail application. Such observations
shall not be construed as an expression on the merits of the case
and shall not influence the trial or any other proceedings in any
manner.
(Sandeep Kumar, J)
Ranjeet/-
U T
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