Patna High Court

Hira Ram @ Hira Lal RamversusThe State of Bihar

Decided: 27 April 2026
Disposal: BAIL GRANTED
Bench: SATYAVRAT VERMA

Holding

The court granted anticipatory bail to the petitioner, subject to bond and surety conditions under Section 482(2) of the B.N.S.

Summary

The petitioner, Hira Ram, applied for anticipatory bail in a case involving multiple offences under Sections 126(2), 115(2), 118(1), 109(1), 76, 303(2), 352, 351(2) and 3(5) of the B.N.S. The counsel highlighted the petitioner’s clean antecedent and argued that the alleged assault resulted in only a simple injury, was not repeated, and the FIR was lodged four days after the incident without a satisfactory explanation. The State opposed the bail, contending the seriousness of the charges. The court noted the delay in FIR registration, the simplicity of the injury, and the petitioner’s clean record, and consequently ordered that the petitioner be released on bail upon surrender, subject to a bond of Rs.10,000 with two sureties and conditions under Section 482(2) of the B.N.S. The application for anticipatory bail was allowed.

Issues considered

Whether anticipatory bail should be granted in a case involving multiple serious offences under the B.N.S.
Whether the four‑day delay in filing the FIR justifies granting bail.
Whether the nature of the alleged injury (simple, non‑repeated) affects the bail decision.

Legislation cited

B.N.S. — s. 109(1), 115(2), 118(1), 126(2), 303(2), 3(5), 351(2), 352, 482(2), 76

Subjects

anticipatory bail
FIR delay
simple injury
land dispute
clean antecedent
Section 482(2) of B.N.S.

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.1244 of 2026
                      Arising Out of PS. Case No.-127 Year-2025 Thana- BAHERI District- Darbhanga
                 ======================================================
                 Hira Ram @ Hira Lal Ram S/o Sahdev Ram R/o Village - Balant, P.S -
                 Baheri, District - Darbhanga

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr.Baidyanath Prasad
                 For the Opposite Party/s :       Mr.Jharkhandi Upadhyay
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
                                       ORAL ORDER

2   27-04-2026                  1. Heard learned counsel for the petitioner and

                   learned APP for the State.

                                2. The petitioner seeks bail in anticipation of his

                   arrest in a case registered for the offences punishable under

                   Sections 126(2), 115(2), 118(1), 109(1), 76, 303(2), 352, 351(2),

                   3(5) of the B.N.S.

                                3. The learned counsel for the petitioner submits that

                   the petitioner is a person with clean antecedent. It is further

                   submitted that Bahuri Devi along with nine others had

                   approached this Court seeking anticipatory bail by filing Cr.

                   Misc. No.47588 of 2025 and the same came to be allowed by an

                   order dated 30.07.2025, but then it is submitted that case of the

                   petitioner is not akin to the case of Bahuri Devi and others as in

                   the FIR, there is specific allegation against the petitioner of
Patna High Court CR. MISC. No.1244 of 2026(2) dt.27-04-2026
                                            2/3




          assaulting informant’s husband by tangari causing injury on

          head while Sanjay assaulted her dewar by tangari causing injury

          on head, but then it is submitted that the injury has been opined

          to be simple and the blow is not alleged to have been repeated

          and the date of occurrence is 07.04.2025 and the FIR came to be

          instituted on 11.04.2025 ie. after delay of four days without any

          plausible explanation It is also submitted that petitioner is not a

          criminal and on account of dispute relating to land the

          occurrence is alleged to have taken place.

                       4. Learned A.P.P. opposes the anticipatory bail

          application.

                       5. Considering the submissions made by the learned

          counsel for the petitioner and taking into the consideration the

          fact that petitioner is a person with clean and the blow is not

          alleged to be repeated and the injury has been opined to be

          simple and the FIR has been instituted after a delay of four days,

          the petitioner, above-named, in the event of his arrest or

          surrender before the learned Court below within a period of six

          weeks, is directed to be released on bail on his furnishing bail-

          bonds in the sum 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/successor Court in
               Patna High Court CR. MISC. No.1244 of 2026(2) dt.27-04-2026
                                                           3/3




                         connection with Baheri P. S. Case No.127 of 2025, subject to

                         the conditions laid down under Section 482(2) of the B.N.S.S.

                                      6. The application stands allowed.



                                                   (Satyavrat Verma, J)
vikash/-

U          T

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