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Patna High Court

Ranjit Kumar @ Ranjeet KumarversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

Holding

The court granted regular bail to the petitioner, finding no direct allegation against him and noting his lack of criminal antecedent.

Summary

The petitioner, Ranjit Kumar, was arrested in connection with an examination fraud case (PS Case No. 334 of 2025) where another individual, Santosh Kumar, allegedly used the petitioner's identity to sit for a driver constable exam. The FIR charges under sections 318(4), 338, 336(2), 340(2), 61(2), 3(5) of the Bhartiya Nyaya Sanhita, 2023 and section 10 of the Bihar Conduct of Examinations Act, 1981, but the complaint primarily targets the co‑accused Santosh Kumar, not the petitioner. The petitioner, who has been in custody since 11‑12‑2025 and has no prior criminal record, contended that he was falsely implicated. The State opposed bail, but the court noted the lack of direct allegations against the petitioner and his status as a mere beneficiary of the alleged crime. Consequently, the court ordered his release on regular bail upon furnishing a bond of Rs.10,000 with two sureties.

Issues considered

  • Whether the petitioner can be held liable for the offences alleged in the FIR under the Bhartiya Nyaya Sanhita, 2023 and the Bihar Conduct of Examinations Act, 1981.
  • Whether regular bail should be granted to the petitioner given the nature of the allegations and his period of custody.

Legislation cited

Subjects

  • regular bail
  • examination fraud
  • impersonation
  • criminal procedure
  • Bhartiya Nyaya Sanhita
  • Bihar Conduct of Examinations Act
  • co‑accused

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.14203 of 2026
                  Arising Out of PS. Case No.-334 Year-2025 Thana- MITHANPURA District- Muzaffarpur
                 ======================================================
                 Ranjit Kumar @ Ranjeet Kumar Son of Shankar Yadav Resident of Village
                 -Shadipur PS -Banshi District -Arwal


                                                                                 ... ... Petitioner/s
                                                      Versus

                 The State of Bihar

                                                                            ... ... Opposite Party/s

                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr.Shailesh Kumar, Advocate
                 For the Opposite Party/s :      Mr.Parmeshwar Mehta, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PARTHA SARTHY
                                       ORAL ORDER

2   12-03-2026                  1. Heard learned counsel for the parties.

                                2. The petitioner has preferred this application for

                   grant of regular bail in connection with Mithanpura P.S. Case

                   no.334 of 2025 registered under sections 318(4), 338, 336(2),

                   340(2), 61(2) and 3(5) of the Bhartiya Nyaya Sanhita, 2023 and

                   section 10 of the Bihar Conduct of Examinations Act, 1981.

                                3. As per the prosecution case, in course of

                   invigilation in the examination being conducted by the Central

                   Selection Board for selection of Driver Constable, it is stated

                   that the invigilator found discrepancy in the Admit Card and

                   Aadhar Card of the appearing candidate namely Santosh Kumar.

                   On enquiry, it transpired that the said Santosh Kumar was
Patna High Court CR. MISC. No.14203 of 2026(2) dt.12-03-2026
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          appearing in the exam in place of this petitioner namely Ranjit

          Kumar.

                       4. Learned counsel for the petitioner submits that the

          petitioner has been falsely implicated in the case. From the

          contents of the FIR itself it would transpire that no allegation of

          any offence having been committed by the petitioner in the

          examination hall has been alleged in the FIR. The allegation, if

          any, is against the co-accused Santosh Kumar and not the

          petitioner herein. The petitioner is in custody since 11.12.2025

          and has no criminal antecedent.

                       5. The application for bail is opposed by learned A.P.P

          for the State.

                       6. Having heard learned counsel for the parties and

          taking into consideration the allegations in the FIR, the

          allegation mainly being against co-accused Santosh Kumar and

          not the petitioner herein who at best can be said to be a

          beneficiary of the crime committed by the co-accused, the

          petitioner having remained in custody since 11.12.2025 and not

          having any criminal antecedent, the petitioner is directed to be

          enlarged on bail in connection with Mithanpura P.S. Case

          no.334 of 2025 on furnishing bail bond of Rs.10,000/- (Rupees

          Ten Thousand) with two sureties of the like amount each to the
             Patna High Court CR. MISC. No.14203 of 2026(2) dt.12-03-2026
                                                         3/3




                       satisfaction of the learned Judicial Magistrate, 1st Class,

                       Muzaffarpur.



                                                   (Partha Sarthy, J)
Shiv/-

U        T


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