Patna High Court

Sanjeet KumarversusThe State of Bihar

Decided: 15 April 2026
Disposal: DISMISSED
Bench: ASHOK KUMAR PANDEY

Holding

Bail was denied to the petitioner.

Summary

The petitioner, Sanjeet Kumar, was charged under Section 140(3) of the B.N.S. for alleged human trafficking after a victim alleged he sold her to a woman named Soni Devi. The victim’s statement, recorded under Section 183 of the BNSS, claimed the petitioner refused to marry her and subsequently sold her. The petitioner contended he was residing in Rajasthan for livelihood and denied kidnapping, but offered no proof of his whereabouts. The State opposed bail, emphasizing the seriousness of the trafficking allegation and the lack of corroborative evidence from the petitioner. The court, after considering the facts, refused to grant bail, directing that the petitioner may reapply after six months if the trial remains pending and urging the trial court to expedite the proceedings.

Issues considered

Whether bail should be granted to the accused under Section 140(3) of the B.N.S. in a human trafficking case.
Whether the evidence and statements on record justify the denial of bail.

Legislation cited

B.N.S. — s. 140(3)
BNSS — s. 183

Subjects

bail
human trafficking
kidnapping
Section 140(3)
Section 183
criminal procedure
expedited trial

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.14087 of 2026
                         Arising Out of PS. Case No.-8 Year-2025 Thana- SIGAUDI District- Patna
                 ======================================================
                 Sanjeet Kumar S/o Rajdev Mochi Resident of Village- Bibipur, P.S.- Sigori,
                 District- Patna

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr.Krishna Deo Raj, Adv.
                 For the Opposite Party/s :       Mr.Md. Matloob Rab, APP-34
                 For the O.P. No. 2       :       Ankita Singh, Advocate.
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ASHOK KUMAR PANDEY
                                       ORAL ORDER

3   15-04-2026                  Heard learned counsel for the petitioner and learned

                   APP for the State.

                                2. The petitioner seeks bail in connection with Sigori

                   P.S. Case No. 08 of 2025 registered for the offence punishable

                   under Section-140(3) of B.N.S.

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

                   daughter of the informant had gone to fill up bona fide form but

                   she did not return for a considerable time. She was being

                   searched. During course of investigation, the victim was

                   recovered and her statement under the provisions of Section-183

                   of the BNSS was recorded wherein she has stated that she was

                   in rrelationmship with the petitioner. He called her to Patna and

                   when she came Patna, the petitioner refused to marry her and
Patna High Court CR. MISC. No.14087 of 2026(3) dt.15-04-2026
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          asked her to return home. It is further alleged that while she was

          crying at the station, a lady arrived there wap was related with

          the petitioner whose name was Soni Devi. It is further alleged

          that the petitioner sold her to Soni Devi and the said Soni Devi

          got solemnized her marriage with one Manoj Singh.

                       4. Learned counsel for the petitioner has submitted

          that during investigation, the police recorded the statement of

          the petitioner wherein he has stated that he was at Rajasthan for

          earning his livelihood and was on talking term with the victim

          but he has not kidnapper her. Learned counsel for the petitioner

          has submitted further that during course of investigation, it has

          come that the petitioner was living at Jaypur, Rajasthan for

          earning his livelihood.

                       5. Per contra, learned counsel for the informant and

          learned APP have vehemently opposed the prayer for bail and

          submitted that the victim has categorically stated that this

          petitioner has sold her to one lady Sona Devi. The allegation

          against the petitioner is of human trafficking and the defence

          which has been taken by the petitioner is not substantiated as he

          has not brought any proof as to where he was working on the

          date of occurrence.

                       6. Considering the aforesaid facts and circumstances,
            Patna High Court CR. MISC. No.14087 of 2026(3) dt.15-04-2026
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                      at this stage, I am not inclined to grant bail to the petitioner and

                      accordingly, the same is rejected.

                                   7. However, the petitioner may renew his prayer for

                      bail after six months if the trial is not concluded.

                                   8. The learned trial court is directed to take all

                      endeavour to conclude the trial of the petitioner expeditiously.



                                            (Ashok Kumar Pandey, J)
A.K.V.//-

U      T

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