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Patna High Court

Chitranjan SinghversusThe State of Bihar

Decided
Disposal
ALLOWED

Holding

The Court held that the petitioner is entitled to regular bail as there is no specific allegation against him and his detention is solely based on his relationship to the accused.

Summary

The petitioner, Chitranjan Singh, was arrested in connection with a murder case (PS Belsand Case No. 187 of 2025) under sections 103(1), 61(2) and 3(5) of the BNS, primarily because he is the father of the alleged shooter, Santanu Singh. The prosecution’s case is based on the informant’s brother discovering a dead body with a gunshot wound, and the informant’s claim that the deceased was being followed by Santanu Singh and others. The petitioner contended that he had no direct involvement, no specific allegation against him, and that his only link to the crime was familial, emphasizing his clean record and the bail already granted to a similarly situated co‑accused, Ram Pravesh Rai. The State opposed the bail, arguing that the petitioner’s relationship to the accused warranted continued detention. The Court, after considering the lack of direct evidence against the petitioner and the precedent of bail to a similar co‑accused, ordered his release on regular bail upon furnishing a bond of Rs.10,000 with two sureties. The order was pronounced by Justice Ashok Kumar Pandey of the Patna High Court.

Issues considered

  • Whether a person can be detained solely on the basis of being a relative of an accused in a murder case.
  • Whether the petitioner is entitled to regular bail under the circumstances of his custody and lack of antecedent.
  • Whether the precedent of bail granted to a similarly situated co‑accused influences the bail decision.

Legislation cited

  • BNS — s. 103(1), 3(5), 61(2)

Subjects

  • regular bail
  • bail jurisdiction
  • relationship liability
  • BNS
  • murder case
  • Patna High Court
  • criminal procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.11058 of 2026
                      Arising Out of PS. Case No.-187 Year-2025 Thana- BELSAND District- Sitamarhi
                 ======================================================
                 Chitranjan Singh S/o Late Ram Ayodhya Singh Resident of Village- Bhorha
                 ward no. 15, P.S.- Belsand, Dist.- Sitamarhi

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :        Mr.Virendra Kumar, Advocate
                 For the Opposite Party/s :        Mr.Arun Kumar Singh, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ASHOK KUMAR PANDEY
                                       ORAL ORDER

3   09-04-2026                       Heard learned counsel for the petitioner and learned

                   APP for the State.

                                2. The petitioner has prayed for regular bail in a case

                   registered for the offence punishable under sections 103 (1), 61

                   (2) and 3 (5) of the BNS.

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

                   brother of the informant informed the informant that he was

                   being followed by Santanu Singh and others and that he was

                   proceeding towards Bhandari. Upon receiving such information,

                   the informant also proceeded towards Bhandari Road, and upon

                   reaching Bhandari–Bhatwaliya Road, he found the dead body of

                   his brother lying in the field of Ram Kishore Rai. It is alleged

                   that the deceased had sustained a gunshot injury on his chest.

                                4. Learned counsel for the petitioner submits that the
Patna High Court CR. MISC. No.11058 of 2026(3) dt.09-04-2026
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          petitioner is innocent and has falsely been implicated in

          connection with the present case. It is further submitted that the

          petitioner has been implicated in the present case solely on the

          basis that he is the father of the named accused, Santanu Singh,

          and there is no specific allegation against him. It is further

          submitted that, at best, the allegation may lie against Shantanu

          Singh for having allegedly shot the deceased, but the petitioner

          has no role in the occurrence and has been falsely implicated

          merely on account of his relationship.

                       5. It is also submitted that a similarly situated co-

          accused, namely Ram Pravesh Rai, who is the father of another

          accused, Deepu, has already been granted bail by a Co-ordinate

          Bench of this Court vide order dated 01.04.2026 passed in Cr.

          Misc. No. 7192 of 2026. The petitioner is in custody since

          27.10.2025 having no criminal antecedent.

                       6. Learned APP has vehemently opposed the prayer

          for bail.

                       7. Considering the aforesaid facts and circumstances

          of the case, this court is inclined to enlarge the petitioner on

          bail. The above named petitioner is directed to be released on

          bail in connection with Belsand P.S. Case No. 187 of 2025 on

          furnishing bail bond of Rs.10,000/- (ten thousand) with two
            Patna High Court CR. MISC. No.11058 of 2026(3) dt.09-04-2026
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                      sureties of the like amount each to the satisfaction of learned

                      Judicial Magistrate, 1st Class, Sitamarhi.



                                             (Ashok Kumar Pandey, J)
Jagdish/-

U       T


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