Patna High Court
Satendra SahniversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- ARUN KUMAR JHA
Holding
The court held that the petitioner is entitled to bail, subject to a bond and conditions, given the lack of incriminating forensic evidence and the risk of false implication.
Summary
The petitioner, Satendra Sahni, sought relief from anticipated arrest in a criminal case (PS Case No.86 of 2025) alleging assault and death of an informant's mother‑in‑law under Sections 103(1) and 3(5) of the BNS. The prosecution claimed the petitioner and co‑accused caused the victim's death, but the post‑mortem report showed no internal or external injuries and the cause of death was pending further investigation. The petitioner argued he was falsely implicated, citing a prior case (PS Case No.81 of 2025) filed by his wife under Section 137(2) against the informant’s sons, and highlighted that co‑accused had been granted anticipatory bail. The State opposed the bail application. Considering the lack of forensic evidence, the possibility of false implication, and the precedent of anticipatory bail to co‑accused, the court ordered the petitioner’s release on bail with a bond of Rs.10,000 and two sureties, subject to conditions under Section 482(2) of the B.N.S.S. and attendance requirements.
Issues considered
- Whether the petitioner is entitled to bail despite the serious nature of the alleged offenses.
- Whether the post‑mortem report negates the prosecution’s claim of homicide.
- Whether the possibility of false implication warrants the grant of bail.
- Whether the conditions imposed under Section 482(2) are appropriate.
Legislation cited
Subjects
- bail
- anticipatory bail
- false implication
- post‑mortem report
- Section 482
- criminal procedure
- Section 103
- Section 3
- Section 137
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.14892 of 2026
Arising Out of PS. Case No.-86 Year-2025 Thana- HIRAMMA P.S. District- Sheohar
======================================================
Satendra Sahni Son of Anup Sahni Resident of Village -Athkoni, Ward no.06,
P.S -Hiramma District -Sheohar
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr.Amrendra Kumar, Advocate
For the Opposite Party/s : Mr.Tarkeshwar Nath Thakur, APP
======================================================
CORAM: HONOURABLE MR. JUSTICE ARUN KUMAR JHA
ORAL ORDER
2 03-04-2026 Heard learned counsel for the petitioner and learned
A.P.P. for the State.
02. In the present case, the petitioner is apprehending
his arrest in connection with Hirarama P.S. Case No. 86 of 2025
registered for the alleged offences under Section 103(1) and 3(5)
of the BNS
03. As per prosecution case, petitioner and other
coaccused persons assaulted the mother-in-law of the informant
who received injuries and was declared brought dead when taken
to the hospital.
04. Learned counsel for the petitioner submits that the
petitioner is innocent and has been falsely implicated in this case.
Prior to lodging of this case, the wife of the petitioner has
instituted Hirarama P.S. Case No. 81 of 2025 under section 137(2),
Patna High Court CR. MISC. No.14892 of 2026(2) dt.03-04-2026
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96, 3(5) of the BNS against the sons of the informant for enticing
away her minor daughter. In order to save their skin, the present
case has been lodged by the informant side. Learned counsel
further submits that though there is allegation of causing death of
the mother-in-law of the informant by assault of the petitioner and
other coaccused persons, no internal or external injuries were
found on the dead body and opinion was reserved in the post
mortem report for cause of death till receipt of report of viscera.
Learned counsel further submits that similarly placed coaccused
persons namely Sangeeta Devi and Anup Sahni have been granted
anticipatory bail by a Coordinate Bench of this Court vide order
dated 01.04.2026 passed in Cr. Misc. No. 15772 of 2026. The
petitioner is having clean antecedent.
05. Learned A.P.P. for the State opposes the submission
made on behalf of the learned counsel for the petitioner.
06. Having regard to the facts and circumstances and
submission made on behalf of the parties and considering the
earlier instituted case of the petitioner side and further considering
the post mortem report which does not show any injury and also
considering possibility of false implication, let the petitioner above
named, in the event of his arrest or surrender before the court
concerned within a period of eight weeks from today, be released
on bail, on furnishing bail bond of Rs. 10,000/- (Rupees Ten
Patna High Court CR. MISC. No.14892 of 2026(2) dt.03-04-2026
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Thousand Only) each with two sureties of the like amount each to
the satisfaction of Court of learned CJM, Sheohar in connection
with Hirarama P.S. Case No. 86 of 2025, subject to the condition
laid down under Section 482(2) of the B.N.S.S. and other
following conditions:
(i) One of the bailors will be a
close relative of the petitioner.
(ii) The petitioner will remain
present on each and every date
fixed by the court below, if so
required by the learned trial
court.
(Arun Kumar Jha, J)
Anuradha/-
U T
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