Patna High Court

Satyam KumarversusThe State of Bihar

Decided: 18 February 2026
Disposal: ALLOWED
Bench: ASHOK KUMAR PANDEY

Holding

The Court granted bail to the petitioner, directing him to furnish a bail bond of Rs.10,000 with two sureties.

Summary

The petitioner, Satyam Kumar, applied for bail in a case registered under Sections 25(1‑B)a, 27 and 25(9) of the Arms Act, alleging that a video showed a birthday party where a single round was fired and that he was falsely implicated. The prosecution relied on the video and a statement that the petitioner was present at the scene, while the defence argued that another individual, identified as Manish, was the actual shooter and that no material evidence was recovered from the petitioner. The petitioner also claimed that the only incriminating material was a confessional statement, which he contended was not reliable. The State opposed bail, citing two prior criminal cases against the petitioner. After hearing both sides, the Court found the evidence insufficient to justify continued detention and ordered the petitioner to be released on bail upon furnishing a bond of Rs.10,000 with two sureties.

Issues considered

Whether bail should be granted to the petitioner accused under the Arms Act based on the available evidence.
Whether the confessional statement and video evidence are sufficient to deny bail.
Whether the petitioner’s prior criminal antecedents warrant denial of bail.

Legislation cited

Arms Act — s. 25(1-B)a, 25(9), 27

Subjects

bail
Arms Act
confessional statement
false implication
criminal procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.12514 of 2026
                  Arising Out of PS. Case No.-145 Year-2025 Thana- Ramgarh Chowk District- Lakhisarai
                 ======================================================
                 Satyam Kumar, Son of Bibhuti Singh, Resident of Village - Sharma, P.S.-
                 Tetarhat District - Lakhisarai.
                                                                         ... ... Petitioner/s
                                                 Versus
                 The State of Bihar
                                                                  ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Arbind Kumar Singh, Advocate
                 For the Opposite Party/s :       Mr. Brajendra Nath Pandey, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ASHOK KUMAR PANDEY
                                       ORAL ORDER

2   18-02-2026                  Heard learned counsel for the petitioner and learned

                   APP for the State.

                                2. The petitioner has prayed for bail in connection with

                   Ramgarh Chowk P.S. Case No. 145 of 2025 registered for the

                   offence punishable under Sections 25(1-B)a, 27 and 25(9) of the

                   Arms Act.

                                3. The case of the prosecution, in short, is that a photo

                   and a video clip were received through mobile in which 18-20

                   persons were celebrating birthday party on an unknown vehicle. In

                   the said party, people were using abusive languages and thereafter

                   one round firing was done on which all the persons were dancing.

                                4. Learned counsel appearing on behalf of the petitioner

                   has submitted that petitioner is innocent and has committed no

                   offence. He has been falsely implicated in this case. It has been

                   submitted by learned counsel for the petitioner that one Manish
             Patna High Court CR. MISC. No.12514 of 2026(2) dt.18-02-2026
                                                         2/2




                       was identified in the video as the person who was firing. When

                       police reached there, it was informed that the petitioner was also

                       there and on that basis, he has been framed in this case. It is also

                       clear from the order of the learned trial Court that the petitioner

                       has also given his confessional statement. It has also been

                       submitted that save and except the confessional statement, nothing

                       is there against the petitioner. Nothing has been recovered from his

                       possession. He is languishing in judicial custody since 18.08.2025.

                                    5. Learned APP appearing for the State has vehemently

                       opposed the application for bail and has submitted that petitioner

                       is having criminal antecedent of two cases.

                                    6. Having heard learned counsel for the parties and

                       considering the facts and circumstances of the case, this Court is

                       inclined to enlarge the petitioner on bail. The above named

                       petitioner is directed to be enlarged on bail on furnishing bail bond

                       of Rs. 10,000/- (Rs. ten thousand only) with two sureties of the

                       like amount each to the satisfaction of the learned Chief Judicial

                       Magistrate, Lakhisarai in connection with Ramgarh Chowk P.S.

                       Case No. 145 of 2025.


                                                         (Ashok Kumar Pandey, J)

lata/-
U        T

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