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Patna High Court

Deolal Sahani @ Devlal SahaniversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

Holding

The Court granted regular bail to the petitioner upon execution of a bail bond and sureties.

Summary

The petitioner, Deolal Sahani, was arrested in connection with a violent robbery and arson incident alleged to have occurred on 22 July 2024, involving looting of valuables worth several crores. He filed a regular bail petition, contending that the FIR contains only vague, omnibus allegations against him and that he has a clean antecedent. The petitioner also relied on a prior anticipatory bail order granted to Shiv Sahani and others in a similar case. The State opposed the bail on the ground of the seriousness of the offences listed under the BNS, 2023. The Court, after considering the submissions, held that the petitioner is entitled to regular bail upon furnishing a bail bond of Rs.10,000 with two sureties of the same amount, and ordered his release pending trial.

Issues considered

  • Whether the petitioner is entitled to regular bail despite the serious nature of the offences alleged in the FIR
  • Whether the general and omnibus nature of the allegations in the FIR precludes the grant of bail
  • Whether the earlier anticipatory bail order in a similar case is determinative for the present bail petition

Legislation cited

  • BNS, 2023 — s. 115(2), 118(1), 190, 191(2)(3), 3, 303(2), 324(2), 326(g), 351(2), 352

Subjects

  • bail
  • regular bail
  • anticipatory bail
  • IPC sections
  • criminal procedure
  • high court

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.1224 of 2026
                  Arising Out of PS. Case No.-182 Year-2024 Thana- BANJARIA District- East Champaran
                 ======================================================
                 Deolal Sahani @ Devlal Sahani S/O Jagdeo sahani R/O Village- Chailaha Tal,
                 P.s.- Banjariya, District- East Champaran
                                                                           ... ... Petitioner/s
                                                     Versus
                 The State of Bihar
                                                                    ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Sunil Kumar No. III, Advocate
                 For the Opposite Party/s :       Mr. Akshay Lal Pandit, A.P.P.
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
                                       ORAL ORDER

2   20-04-2026                  1. Heard learned counsel for the petitioner and

                   learned A.P.P. for the State.

                                2. The petitioner seeks bail in a case registered for the

                   offences punishable under Sections 190, 191(2)(3), 115(2),

                   118(1), 303(2), 324(2), 326(g), 352, 351(2) and 3 of the BNS,

                   2023.

                                3. Learned counsel for the petitioner submits that

                   petitioner is a person with clean antecedent and is aged about 55

                   years and the informant alleges that on 22.07.2024, at 07:00

                   p.m., she heard hulla, accordingly, came out of the house and

                   saw the named accused persons including the petitioner along

                   with 200 unknown accused persons. Further, on orders of

                   Bhagirath, accused persons entered the shop of the informant

                   and looted articles worth Rs.50 lakhs and even assaulted her

                   father-in-law. Further, Ajay, Sonalal and Pradip entered her
Patna High Court CR. MISC. No.1224 of 2026(2) dt.20-04-2026
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          house and took ornaments worth Rs.7 lakhs along with LIC

          policy, while Prabhu, Jay Prakash, Shatrughan, Sunil and Suresh

          looted four laptops and pen-drive worth Rs.2 lakhs and the

          accused persons set the shop on fire causing loss of Rs.1 crore

          and also set ablaze five motorcycles. It is next alleged that there

          is a land dispute with the cousin father-in-law, namely, Raj

          Kumar of the informant and the occurrence was committed at

          his behest.

                       4. Learned counsel for the petitioner submits that

          petitioner is in custody since 21.09.2025 and from perusal of the

          allegation as alleged in the FIR, it would manifest that no

          specific allegation is alleged against the petitioner rather

          allegation is general and omnibus in nature. It is further

          submitted that Shiv Sahani along with six others had

          approached this Court seeking anticipatory bail by filing Cr.

          Misc. No. 79730 of 2025 and the same came to be allowed vide

          order dated 08.12.2025 by this Court. It is next submitted that

          case of the petitioner if not akin is similar to the case of Shiv

          Sahani and others. It is also submitted that if the privilege of

          regular bail is granted to the petitioner, the petitioner will not

          abscond rather will cooperate in the trial to prove his innocence.

                       5. Learned A.P.P. for the State opposes the prayer for
           Patna High Court CR. MISC. No.1224 of 2026(2) dt.20-04-2026
                                                       3/3




                     regular bail of the petitioner.

                                  6. Considering the submissions made by the learned

                     counsel appearing on behalf of the petitioner, the petitioner,

                     above-named, is directed to be released on bail on furnishing

                     bail bonds of Rs.10,000/- (Rupees Ten Thousand) with two

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

                     Trial Court where the case is pending in connection with

                     Banjariya P.S. Case No. 182 of 2024.


                                                                         (Satyavrat Verma, J)

Kundan/-

U     T


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