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Patna High Court

Renu DeviversusThe State of Bihar

Decided
Disposal
DISMISSED

Holding

Bail was not granted to the petitioner at this stage of the proceedings.

Summary

The petitioner, Renu Devi, was arrested in connection with a human‑trafficking case (Rajgir P.S. Case No. 454 of 2025) under Sections 137(2), 142, 98 and 99 of the Bihar Narcotic and Smuggling Act, 2023. The victim’s statement under Sections 180 and 183 of the same Act alleged that the petitioner was part of a racket that abducted the victim, handed her over to intermediaries and ultimately to a person named Chhotu. The State opposed bail, arguing that the petitioner’s involvement was clear and that bail had already been denied to co‑accused Rahul Kumar and Md. Babar in similar matters. The court, after hearing both sides, held that the seriousness of the offence and the petitioner’s alleged role warranted denial of bail at this stage, though she may re‑apply after six months if the trial remains pending. The trial court was directed to expedite the proceedings.

Issues considered

  • Whether bail should be granted to the accused in a human‑trafficking case involving alleged participation in a trafficking racket.
  • Whether the victim’s statement under Sections 180 and 183 of the BNSS is sufficient to deny bail.

Subjects

  • bail
  • human trafficking
  • criminal procedure
  • victim statement
  • BNSS 2023
  • sections 137, 142, 98, 99
  • trial expeditious

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.10410 of 2026
                       Arising Out of PS. Case No.-454 Year-2025 Thana- RAJGIR District- Nalanda
                 ======================================================
                 Renu Devi Wife of Late Binod Das Resident of Vill.- Chittabadi, P.S.-
                 Muffasil, District - Katihar, State - Bihar.

                                                                                   ... ... Petitioner/s
                                                       Versus
                 The State of Bihar

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Gaurav Kumar Verma
                 For the Opposite Party/s :       Mr. Sanjay Kumar Singh
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ASHOK KUMAR PANDEY
                                       ORAL ORDER

3   10-04-2026                  Heard learned counsel for the petitioner and learned

                   APP for the State.

                                2. The petitioner has prayed for bail in connection

                   with Rajgir P.S. Case No. 454 of 2025 registered for the offence

                   punishable under Sections 137(2), 142, 98, 99 of the B.N.S.,

                   2023.

                                3. The case of the prosecution, in short, is that the

                   minor daughter of the informant had gone out of the house to

                   ease herself, and as she did not return for a considerable time,

                   she was being searched.

                                4. Learned counsel for the petitioner submits that

                   during the course of the investigation, the victim was recovered,

                   and she has given her statement recorded under Sections 180 &

                   183 of the BNSS. In her statement under Section 183 of the
Patna High Court CR. MISC. No.10410 of 2026(3) dt.10-04-2026
                                            2/3




          BNSS, the victim has stated that she was having an affair

          outside marriage with one Rahul Kumar. He forcefully took her

          to the baandh. One Dharmendra Kumar was called there.

          Dharmendra Kumar brought a four-wheeler, and both Rahul

          Kumar and Dharmendra have forcefully boarded her in that

          four-wheeler. After that Rahul Kumar left the four-wheeler.

          Dharmendra Kumar took her to Rajgir railway station, and he

          parked his vehicle at Rajgir railway station and took her in a

          train, and there she met one lady who kept her in a room for

          twenty days and then handed her over to Md. Babar, and from

          Md. Babar she was handed over to Chhotu. He further submits

          that the petitioner is a lady. The investigation in this case has

          been completed. Moreover, statement has been made in para 3

          of the petition that petitioner has no criminal antecedent and she

          is languishing in judicial custody since 22.09.2025.

                       5.The application for bail is vehemently opposed by

          the learned counsel for the informant and the learned APP for

          the State. Learned counsel for the informant has submitted that

          from perusal of the statement of the victim recorded under

          Section 183 of the BNSS, it is clear that this petitioner is a

          member of a racket that indulges in human trafficking, and first

          of all, the victim was kept with this petitioner, who has handed
           Patna High Court CR. MISC. No.10410 of 2026(3) dt.10-04-2026
                                                       3/3




                     her over to Md. Babar, and Md. Babar has handed her over to

                     one Chhotu. He also submits that the petitioner, who is involved

                     in the said occurrence, and her complicity is quite clear. He

                     further submits that the bail petitions of similarly situated co-

                     accused persons namely, Rahul Kumar and Md. Babar have

                     already been rejected by this court vide Cr. Misc. Nos. 1230 of

                     2026 and 89054 of 2025 respectively.

                                  6. Having heard learned counsel for the parties and

                     considering the facts and circumstances of the case, this Court is

                     not inclined to enlarge the petitioner on bail at this stage,

                     however she may renew his prayer for bail after six months if

                     the trial is not concluded. Learned trial court is directed to

                     expedite the trial.



                                                    (Ashok Kumar Pandey, J)
Sudhanshu/-

U      T


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