Patna High Court

Manish KumarversusThe State of Bihar

Decided: 8 April 2026
Disposal: ALLOWED
Bench: ASHOK KUMAR PANDEY

Holding

The Court granted regular bail to the petitioner.

Summary

Manish Kumar was arrested in connection with a case registered under several serious offences of the Bhartiya Nyaya Sanhita, 2023, based on police testimony that he fled the scene and mobile phones recovered from him contained WhatsApp chats showing financial transactions of strangers. The petitioner contended that he was falsely implicated due to village politics, no incriminating article was found on him, and that co‑accused in similar circumstances had been granted bail. He had been in judicial custody since 25‑11‑2025 and had no prior criminal record. The State opposed the bail application. The High Court, after considering the facts and the lack of direct evidence, ordered the petitioner to be released on regular bail upon furnishing a bond of Rs.10,000 with two sureties.

Issues considered

Whether the petitioner is entitled to regular bail despite the serious charges under the Bhartiya Nyaya Sanhita, 2023.
Whether the mobile phone evidence and alleged financial transactions constitute sufficient ground to deny bail.
Whether precedent of bail granted to co‑accused in similar cases warrants granting bail to the petitioner.

Legislation cited

Bhartiya Nyaya Sanhita, 2023 — s. 111, 303(2), 318(2), 318(4), 336(2), 336(3), 338, 340(2)

Subjects

regular bail
criminal procedure
Bhartiya Nyaya Sanhita
false implication
political motive
mobile phone evidence
judicial custody

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.12542 of 2026
                 Arising Out of PS. Case No.-478 Year-2025 Thana- NAWADA MUFFASIL District- Nawada
                 ======================================================
                 Manish Kumar S/o Jaynath Prasad Resident of Village- Guramha, P.S.-
                 Muffassil, Dist.- Nawada                           ... ... Petitioner/s
                                              Versus
                 The State of Bihar Bihar                   ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr.Pramod Kumar Verma, Advocate
                 For the Opposite Party/s :      Mr.Ram Priya Sharan Singh, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ASHOK KUMAR PANDEY
                                       ORAL ORDER

3   08-04-2026                       Heard learned counsel for the parties.

                                2. The petitioner has preferred this application for

                   grant of regular bail in connection with Muffasil P.S. Case no.

                   478 of 2025 registered under sections 303(2) 318(2), 318(4),

                   336(2), 336(3), 338, 340(2) and 111 of the Bhartiya Nyaya

                   Sanhita, 2023.

                                3. As per the prosecution case, the informant states

                   that seeing the police personnel, the accused persons started to

                   run away. In the first raid conducted, one person namely Vallabh

                   Raj was arrested from whose possession certain articles were

                   recovered. In the second raid conducted in the village Garmha

                   Badhar, two other persons including the petitioner herein were

                   arrested. It is further stated that on search two mobile phones

                   were recovered from the possession of the petitioner. Further on

                   seeing the WhatsApp chat in the mobile phone recovered from

                   the possession of the petitioner, certain screenshots of the
            Patna High Court CR. MISC. No.12542 of 2026(3) dt.08-04-2026
                                                        2/2




                      financial transactions of strangers were present.

                                   4. Learned counsel for the petitioner submits that the

                      petitioner has been falsely implicated in the case due to village

                      politics. No incriminating article has been recovered from the

                      petitioner's possession. It is further contended that similarly

                      situated co-accused persons has been granted bail by a co-

                      ordinate Bench of this Court vide order dated 12.03.2026 passed

                      in Cr. Misc. No. 13334 of 2026. It is further submitted that the

                      petitioner is in judicial custody since 25.11.2025 having no

                      criminal antecedent.

                                   5. Learned APP appearing for the state has opposed

                      the prayer of regular bail.

                                   6. Considering the aforesaid facts and circumstances

                      of the case, this court is inclined to enlarge the petitioner on

                      bail. The above named petitioner is directed to be released on

                      bail in connection with Muffasil P.S. Case No. 478 of 2025 on

                      furnishing bail bond of Rs.10,000/- (ten thousand) with two

                      sureties of the like amount each to the satisfaction of learned

                      ACJM -1st Nawada.


                                            (Ashok Kumar Pandey, J)
Jagdish/-

U       T

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