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Patna High Court

Manjeet Kumar @ Manjeet Singh @ PrinceversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

Holding

Bail was granted as the petitioner’s name was absent from the FIR and the only incriminating material was an uncorroborated confessional statement.

Summary

Manjeet Kumar (Petitioner) was arrested in connection with a murder case (FIR No. 161/2017) alleging offences under IPC sections 302, 324, 120B, 34 and Arms Act section 27. The petitioner contended that he was not named in the FIR and his alleged involvement stemmed solely from a confessional statement made by co‑accused Numan Jha, which he argued had no evidentiary value. The State opposed bail, relying on the seriousness of the charges. The Court examined the material on record, noted the absence of the petitioner’s name in the FIR and the reliance on an uncorroborated confessional statement, and held that such evidence was insufficient to justify denial of bail. Consequently, the Court ordered the petitioner’s release on regular bail upon furnishing a bond of Rs.10,000 with two sureties of equal amount.

Issues considered

  • Whether bail can be granted when the accused is not named in the FIR and is implicated only through a confessional statement of a co‑accused.

Legislation cited

Subjects

  • bail
  • confessional statement
  • FIR
  • evidentiary value
  • IPC
  • Arms Act
  • regular bail

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.11640 of 2026
                    Arising Out of PS. Case No.-161 Year-2017 Thana- SHASTRINAGAR District- Patna
                 ======================================================
                 Manjeet Kumar @ Manjeet Singh @ Prince S/o Mahakant Ishwar R/o Village
                 - Bharaul Agapur, Ward No. 2, P.S - Bachhawara, District - Begusarai

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr. Sabal Kumar Jha, Advocate
                 For the Opposite Party/s :      Mr. Uday Chand Prasad , APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                       ORAL ORDER

3   13-05-2026                  Heard learned counsel for the petitioner and learned

                   Additional Public Prosecutor for the State .

                                2. The petitioner seeks regular bail registered for the

                   offence punishable under Sections 302/324/120B/34 of the

                   Indian Penal Code and Section 27 of the Arms Act.

                                3. As per F.I.R. informant alleged that on 24.03.2017,

                   all the accused persons shot dead the son of informant.

                                 4. Learned counsel for the petitioner submits that he

                   is not named in the FIR and his name has surfaced on the basis

                   of the confessional statement of co-accused person namely,

                   Numan Jha which has no evidentiary value. Save and except,

                   confessional statement, there is no other material on record to

                   show the involvement of this petitioner in the alleged

                   occurrence . Petitioner is in custody since 26.08.2025 .
            Patna High Court CR. MISC. No.11640 of 2026(3) dt.13-05-2026
                                                        2/2




                                   5. Learned APP for the State opposed the bail.

                                   6. Considering the fact that petitioner is not named in

                      the F.I.R., material available on record and circumstances and

                      that the petitioner’s name has surfaced on the basis of the

                      confessional statement made before the police, let the petitioner

                      above named be released on bail, on furnishing bail bonds of

                      Rs.10,000/- (Ten Thousand) with two sureties of the like amount

                      each to the satisfaction of learned A.C.J.M. IX, at Patna, in

                      connection with Shastrinagar P.S. Case No. 161/2017 .



                                            (Prabhat Kumar Singh, J)
Koushik/-

U      T


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