Patna High Court

SANIA PRIYADARSIversusTHE STATE OF BIHAR

Decided: 24 February 2026
Disposal: DISPOSED
Bench: SATYAVRAT VERMA

Holding

The Court granted provisional anticipatory bail subject to bond, sureties and verification of antecedent, to be confirmed if no prior case is found.

Summary

The petitioner, Sania Priyadarsi, sought anticipatory bail fearing arrest in a case under Section 30(a) of the Bihar Excise Act concerning the alleged recovery of 15 litres of liquor from a scooty she owned. She argued she had a clean antecedent, was not in possession of the liquor, and was unaware that a third party, Vivek, misused her vehicle. The State opposed the bail. The High Court, applying its inherent powers under Section 482(2) of the BNSS, granted provisional anticipatory bail conditioned on a Rs. 500 bond, two sureties, and verification of her criminal antecedent. The order stipulated that if any antecedent is discovered, the bail would not be confirmed; otherwise, it would be confirmed forthwith.

Issues considered

Whether the petitioner is entitled to anticipatory bail under Section 482(2) of the BNSS in a case under Section 30(a) of the Bihar Excise Act
Whether ownership of the vehicle used in the alleged offence suffices to justify anticipatory bail

Legislation cited

BNSS — s. 482(2)

Subjects

anticipatory bail
Bihar Excise Act
Section 30(a)
Section 482(2)
vehicle ownership
clean antecedent

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.11980 of 2026
                       Arising Out of PS. Case No.-584 Year-2025 Thana- RUPASPUR District- Patna
                 ======================================================
                 Sania Priyadarsi Wife Of Sri Lakshmi Narayan @ Lakshmi Narayan Ram
                 R/O Village- Haridaspur, P.S.- Khagaul, District- Patna

                                                                                   ... ... Petitioner/s
                                                       Versus
                 The State Of Bihar Patna

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr.Alok Kumar Sinha
                 For the Opposite Party/s :       Mr.Nitya Nand Tiwary
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
                                       ORAL ORDER

2   24-02-2026               1.    Heard learned counsel for the petitioner and

                   learned A.P.P. for the State.

                             2.    The petitioner apprehends her arrest in a case

                   registered for the offences punishable under Section 30(a) of the

                   Bihar Excise Act.

                             3.    Learned counsel for the petitioner submits that the

                   petitioner is a person with clean antecedent and is a woman and

                   allegation is of recovery of 15 litres of liquor from a Scooty.

                             4.    Learned counsel for the petitioner submits that the

                   petitioner was not arrested from the spot as such nothing was

                   recovered from her conscious possession and she came to be

                   implicated based on the fact that she is owner of the seized

                   vehicle. It is next submitted that no prudent person would use

                   her own vehicle for committing an occurrence and thus would
Patna High Court CR. MISC. No.11980 of 2026(2) dt.24-02-2026
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          create evidence against herself and hence would get implicated,

          it is further submitted that petitioner was completely unaware

          that Vivek would misuse the vehicle in the manner as alleged,

          who was also apprehended from the spot along with Ricky.

                   5.     Learned A.P.P. for the State opposes the prayer for

          anticipatory bail of the petitioner.

                   6.     Considering the submissions made by the learned

          counsel for the petitioner, the petitioner above-named, in the

          event of her arrest or surrender within a period of six weeks

          from today, be released on Provisional anticipatory bail on

          furnishing bail bonds of Rs. 500/- (Rupees Five Hundred) with

          two sureties of the like amount each to the satisfaction of the

          learned trial court where the case is pending/successor court in

          connection with Rupaspur P.S. Case No. 584 of 2025, subject to

          the conditions as laid down under Section 482(2) of the BNSS.

                   7.     It is made clear that thereafter the learned Trial Court

          shall verify the criminal antecedent of the petitioner and in the

          event if it is found that petitioner has antecedent of even one case

          then it would be presumed that petitioner, for the purposes of

          seeking anticipatory bail, had concealed her antecedent before this

          Court, as such, the provisional anticipatory bail order shall not be

          confirmed, but after verification if it is found that petitioner is a

          person with clean antecedent in that event the provisional
              Patna High Court CR. MISC. No.11980 of 2026(2) dt.24-02-2026
                                                          3/3




                        anticipatory bail order shall be confirmed forthwith.



                                                  (Satyavrat Verma, J)
Sumit/-

U         T

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