Patna High Court

Satish Mandal @ Baba @ Raju BhuiyanversusThe State of Bihar

Decided: 27 February 2026
Disposal: ALLOWED
Bench: ASHOK KUMAR PANDEY

Holding

The court granted regular bail to the petitioner, subject to bond and surety conditions.

Summary

The petitioner, Satish Mandal, sought regular bail in a case registered under section 310(2) of the BNS for alleged involvement in a robbery where seven armed men looted Rs.91,000 from a woman’s house. The prosecution alleged that the petitioner had made a confessional statement linking him to the crime, though no other material evidence was presented. The petitioner contended his innocence, argued that the FIR was against unknown miscreants, and highlighted that a co‑accused in a similar case had been granted bail. Despite having 13 prior criminal cases and being in custody since May 2025, the court considered the lack of substantive evidence beyond the confession and the precedent of the co‑accused’s bail. Consequently, the court ordered his release on bail upon furnishing a Rs.10,000 bond with two sureties and imposed conditions of trial cooperation and weekly police station attendance.

Issues considered

Whether the petitioner is entitled to regular bail despite the seriousness of the offence under section 310(2) BNS and his criminal antecedents.
Whether the confessional statement alone suffices to deny bail in the absence of other material evidence.
Whether the bail granted to a similarly situated co‑accused is persuasive authority for granting bail in the present case.

Legislation cited

Bihar Negotiable Instruments Act — s. 310(2)

Subjects

regular bail
confessional statement
criminal antecedents
section 310(2) BNS
bail conditions
trial cooperation

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.12569 of 2026
                         Arising Out of PS. Case No.-41 Year-2025 Thana- GURUA District- Gaya
                 ======================================================
                 Satish Mandal @ Baba @ Raju Bhuiyan S/o Late Karu Mandal @ Manu
                 Mandal @ Manu Bhuiyan R/o Village - Pathalkatti (Gopalpur), P.S -
                 Sherghati, District - Gaya

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr.Paras Nath, Advocate
                 For the Opposite Party/s :       Mr.Renuka Ratnkar (App.125), APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ASHOK KUMAR PANDEY
                                       ORAL ORDER

2   27-02-2026                     Heard learned counsel for the petitioner and learned

                   APP for the State.

                                2. The petitioner has prayed for regular bail in a case

                   registered for the offence punishable under sections 310 (2) of

                   the BNS.

                                3. The case of the prosecution, in brief, is that while

                   the informant was alone in her house along with her children,

                   seven criminals entered the house, overpowered her at gunpoint

                   and took away a sum of Rs. 91,000/- from her CSP centre.

                                4. Learned counsel for the petitioner submits that the

                   petitioner is innocent and has falsely been implicated in

                   connection with the present case. It is further submitted that the

                   F.I.R. was lodged against unknown miscreants and that the
Patna High Court CR. MISC. No.12569 of 2026(2) dt.27-02-2026
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          petitioner was remanded in this case from Gurua P.S. Case No.

          72 of 2025, wherein he is alleged to have made a confessional

          statement. It is contended that save and except the said

          confessional statement, there is no material against the

          petitioner and no recovery has been made from his possession.

          It is further submitted that a similarly situated co-accused has

          been granted bail by this Court vide order dated 12.02.2026

          passed in Cr. Misc. No. 7711 of 2026. The petitioner is having

          criminal antecedents of 13 cases and is in custody since

          08.05.2025.

                        5. Learned A.P.P. has vehemently opposed the prayer

          for 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 Gurua P.S. Case No. 41 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

          Chief Judicial Magistrate, Sherghati, Gaya, with the condition

          that he shall cooperate in the trial, remain physically present on

          each and every date fixed by the trial court, and mark his

          attendance once every week at Barachatti Police Station until
            Patna High Court CR. MISC. No.12569 of 2026(2) dt.27-02-2026
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                      conclusion of the trial.



                                            (Ashok Kumar Pandey, J)
Jagdish/-

U       T

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