Patna High Court
Jyoti YadavversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- ARUN KUMAR JHA
Holding
Bail was granted because the allegations were non‑specific, the petitioner is a young adult with a clean record, and the custody period was short.
Summary
The petitioner, Jyoti Yadav, an 18‑year‑old girl, was arrested in connection with a case alleging trafficking of minor girls and related offences under the B.N.S., POCSO, Juvenile Justice and Bonded Labour Acts. She pleaded that she was falsely implicated, had no involvement in the alleged exploitation, and possessed a clean antecedent. The State opposed bail, contending that she and co‑accused had been bringing minor girls from other states. The court noted the non‑specific nature of the allegations against her, her young age, clean record, and the relatively short period of custody. Accordingly, the court granted bail on a bond of Rs.10,000 with two sureties, subject to conditions under Section 480(3) of the B.N.S.S. and other standard bail conditions.
Issues considered
- Whether bail should be granted to the petitioner despite charges under multiple statutes including the B.N.S., POCSO, Juvenile Justice and Bonded Labour Acts
- Whether the allegations against the petitioner are sufficiently specific to justify denial of bail
- Whether the petitioner’s age, clean antecedent and period of custody warrant bail
Legislation cited
- B.N.S., 2023 — s. 111(4), 143(2), 145, 3(5), 74
- B.N.S.S. — s. 480(3)
- POCSO Act — s. 8
Subjects
- bail
- trafficking of minors
- POCSO
- juvenile justice
- bonded labour
- criminal procedure
- age of accused
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.1491 of 2026
Arising Out of PS. Case No.-676 Year-2025 Thana- RAJGIR District- Nalanda
======================================================
Jyoti Yadav D/o Rajkiran Yadav @ Raj Karan Yadav, R/V- Fatehpur, PS-
Bahua, Dist- Sahfatepur, Uttar Pradesh.
... ... Petitioner
Versus
The State of Bihar
... ... Opposite Party
======================================================
Appearance :
For the Petitioner/s : Mr. Anuj Kumar, Advocate
For the Opposite Party/s : Mr. Manoj Kumar, APP
======================================================
CORAM: HONOURABLE MR. JUSTICE ARUN KUMAR JHA
ORAL ORDER
2 15-01-2026 Heard learned counsel for the petitioner and learned
A.P.P. for the State.
2. In the present case, the petitioner seeks bail in
connection with Rajgir P.S. Case No. 676 of 2025 dated
03.12.2025, registered for the offences punishable under
Sections 143(2), 145, 74 and 111(4) read with Section 3(5) of
the B.N.S., 2023 and Section 8 of the POCSO Act and Sections
75 and 79 of the J.J. Act and Sections 16, 17 and 18 of the
Bonded Labor System (Abolition) Act.
3. As per the prosecution case, petitioner was
apprehended with other co-accused persons with allegation of
trafficking minor girls and supplying them to some orchestra
company where the minor girls were being exploited.
4. Learned counsel appearing on behalf of the
petitioner submits that petitioner is just a girl aged about 18
Patna High Court CR. MISC. No.1491 of 2026(2) dt.15-01-2026
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years and she has falsely been implicated in the present case.
There is no allegation of any sexual assault against the minor
girls. The petitioner is not engaged in exploitation of minor girls
or cruelty against any child. In fact, the petitioner has no
concern either with the co-accused persons or with the orchestra
company. The allegation are general and vague. Learned
counsel lastly submits that petitioner is having clean antecedent
and she is in custody since 04.12.2025.
5. Learned A.P.P. appearing on behalf of the State
opposes the submissions made on behalf of the petitioner and
submits that petitioner and other co-accused persons used to
bring minor girls from other States.
6. Having regard to the facts and circumstances and
submissions made on behalf of the parties and considering the
fact that petitioner is stated to be girl aged about 18 years and
further considering the non-specific nature of allegation against
the petitioner and also considering her clean antecedent and her
period of custody, the petitioner, above-named, is directed to be
released on bail, on furnishing bail bonds of Rs.10,000/-
(Rupees Ten Thousand Only) with two sureties of the like
amount each to the satisfaction of learned Exclusive Special
Judge, POCSO, Biharsharif at Nalanda / concerned Court, in
Patna High Court CR. MISC. No.1491 of 2026(2) dt.15-01-2026
3/3
connection with Rajgir P.S. Case No. 676 of 2025, subject to
the condition laid down under Section 480(3) 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.
(iii) In case of absence on three consecutive dates
or in violation of the terms of the bail, the bail bond of the
petitioner will be liable to be cancelled by the Court concerned.
(iv) The petitioner will remain present physically
till framing of charge.
(Arun Kumar Jha, J)
Shahnawaz/-
U T
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