Patna High Court
Sitaram SahaniversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- PRABHAT KUMAR SINGH
Holding
The Court granted bail to the petitioner, subject to a bail‑bond and sureties.
Summary
The petitioner, Sitaram Sahani, sought bail in a criminal case (PS No. 398 of 2025) where he was accused, along with others, of murdering the daughter of an informant on 09‑08‑2025 and concealing the body. The body was later recovered after a co‑accused disclosed its location. The petitioner, the deceased's father‑in‑law, claimed he had no involvement in the crime, no prior criminal record, and had been in custody since 12‑12‑2025. The State opposed bail, citing the seriousness of the charges under Sections 103(1), 238 and 3(5) of the Bharatiya Nyaya Sanhita. The Court, after considering the nature of the accusation and the period of custody, ordered the petitioner’s release on bail upon furnishing a bail‑bond of Rs.10,000 with two sureties, subject to the satisfaction of the SDJM, Bettiah.
Issues considered
- Whether the petitioner is entitled to bail despite the serious nature of the offences under the Bharatiya Nyaya Sanhita.
Legislation cited
- Bharatiya Nyaya Sanhita — s. 103(1), 238, 3(5)
Subjects
- bail
- criminal law
- murder
- evidence tampering
- high court
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.10567 of 2026
Arising Out of PS. Case No.-398 Year-2025 Thana- NAUTAN District- West Champaran
======================================================
Sitaram Sahani Son of Bhukhal Sahani Resident of Village- Maduwaha Tola
Sihuliya, P.S.- Nautan, District- West Champaran
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr.Sarvesh Kashyap
For the Opposite Party/s : Mr.Aditya Narayan Singh.1
======================================================
CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
ORAL ORDER
2 18-02-2026 Heard learned counsel for the petitioner and learned
A.P.P. for the State.
2. The petitioner seeks bail in a case registered for
offence under Sections 103(1), 238, 3(5) of the Bharatiya Nyaya
Sanhita.
3. It is alleged that all the F.I.R. named accused
persons, including this petitioner, killed the daughter of
informant on 09.08.2025 and concealed the dead body to
destroy the evidence. Dead body of the deceased was recovered
on the disclosure of co-accused Jhunna Ansari, in a white
coloured bag on 13.08.2025.
4. Petitioner is father-in-law of the deceased. He is
separate in mess & property and has got no concern with the
affairs of the deceased. Thrust of the allegation is against
husband of the deceased, who is already in custody since
Patna High Court CR. MISC. No.10567 of 2026(2) dt.18-02-2026
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14.08.2025. Petitioner is in custody since 12.12.2025 and has
got no criminal antecedent. Chargesheet has been submitted.
5. Learned A.P.P. for the State opposes the prayer for
bail.
6. Considering the nature of accusation and period of
custody, let the above named petitioner be released on bail on
furnishing bail-bond of Rs. 10,000/- (ten thousand) with two
sureties of the like amount each to the satisfaction of learned
S.D.J.M., Bettiah, West Champaran in connection with Nautan
P.S. Case No. 398 of 2025.
(Prabhat Kumar Singh, J)
anay
U T
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