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Patna High Court

Triloki ManjhiversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

Holding

The court granted bail to the petitioners subject to a Rs 30,000 bond each and verification of criminal antecedents.

Summary

The petitioners, who are family members, sought anticipatory bail fearing arrest in a case (Chapra Muffasil P.S. Case No. 597/2025) alleging assault on the informant's daughter with a wood‑cutting weapon. The FIR listed offences under the Bharatiya Nyaya Sanhita, 2023, but the petitioners claimed innocence, stating the incident arose from a local dispute over garbage and that the FIR lacked motive. The State opposed bail, while the petitioners argued they had no criminal antecedent (except two accused in another case). The High Court noted that the trial court had described the injuries as simple and caused by a blunt object, and therefore granted bail on the condition of a Rs 30,000 bond per petitioner, verification of antecedents, and compliance with sections of the Bharatiya Nagrik Suraksha Sanhita, 2023. The order also directed that bail bonds not be delayed for verification and that the trial court may cancel bail if antecedents are concealed.

Issues considered

  • Whether anticipatory bail should be granted to the petitioners under the Bharatiya Nagrik Suraksha Sanhita, 2023.
  • Whether the nature of injuries and the contents of the FIR justify denial of bail.
  • What conditions may be imposed on bail under sections 2(1)(d) and 482(2) of the Bharatiya Nagrik Suraksha Sanhita, 2023.

Legislation cited

Subjects

  • anticipatory bail
  • bail
  • criminal procedure
  • Bharatiya Nyaya Sanhita
  • Bharatiya Nagrik Suraksha Sanhita
  • assault
  • simple injuries

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.15426 of 2026
                  Arising Out of PS. Case No.-597 Year-2025 Thana- CHAPRA MUFFASIL District- Saran
                 ======================================================
           1.     Triloki Manjhi S/O Late Hardev Manjhi R/O Village- Itahiya, P.S.- Chapra
                  Muffasil, District- Saran
           2.    Sanju Devi W/O Triloki Manjhi R/O Village- Itahiya, P.S.- Chapra Muffasil,
                 District- Saran
           3.    Amit Kumar S/O Triloki Manjhi R/O Village- Itahiya, P.S.- Chapra Muffasil,
                 District- Saran

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr.Harish Kumar, Advocate
                 For the Opposite Party/s :      Ms.Gulnar Begum, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE DR. ANSHUMAN
                                       ORAL ORDER

2   25-03-2026                    Heard learned counsel for the petitioners and learned

                   APP for the State.

                                2. The petitioners who apprehend arrest in connection

                   with Chapra Muffasil P.S. Case No. 597/2025 lodged

                   01.11.2025, for the offences punishable under sections 126(2),

                   115(2), 118(1), 109, 351(2)3(5) of the Bharatiya Nyaya Sanhita,

                   2023.

                                3. As per the prosecution, the F.I.R. has been lodged

                   against four named accused persons, including the petitioners,

                   alleging therein that they assaulted the daughter of the informant

                   with a wood-cutting weapon, as a result of which she sustained
Patna High Court CR. MISC. No.15426 of 2026(2) dt.25-03-2026
                                            2/3




          serious injuries.

                       4. Learned counsel for the petitioners submits that the

          petitioners are innocent and have committed no offence. It is

          further submitted that neither any reason nor motive for the

          alleged occurrence has been stated in the F.I.R. The informant

          and the petitioners are residents of the same locality, and due to

          an altercation over throwing garbage in a public place, a scuffle

          took place. In retaliation, the present F.I.R. has been lodged with

          frivolous allegations. Learned counsel further submits that

          petitioner no. 1 has no criminal antecedent, whereas petitioner

          nos. 2 and 3 are accused in one other criminal case.

                       5. Learned A.P.P. for the State opposes the prayer for

          bail.

                       6. Considering the fact that the order rejecting the

          anticipatory bail of the petitioners by the learned Trial Court

          reflects that the injuries are simple in nature, caused by a hard

          and blunt substance, and are present over the body,, let the

          above-named petitioners be released on bail, in the event of

          their arrest or surrender before the Trial Court within a period of

          four weeks from today, on furnishing bail bond of ₹30,000/-

          (Rupees Thirty Thousand only) each, as mentioned in Section

          2(1)(d) of the Bharatiya Nagrik Suraksha Sanhita, 2023, to the
            Patna High Court CR. MISC. No.15426 of 2026(2) dt.25-03-2026
                                                        3/3




                      satisfaction of the learned CJM, Saran, Chapra, in

                      connection with the aforementioned case, subject to the

                      conditions as laid down under Section 482(2) of the Bharatiya

                      Nagrik Suraksha Sanhita, 2023.

                                   7. And further condition that the trial court shall verify

                      the criminal antecedent of the petitioner and in case at any stage

                      it is found that the petitioner has concealed his criminal

                      antecedent, the trial court shall take step for cancellation of bail

                      bond of the petitioner. However, the acceptance of bail bonds in

                      terms of the above-mentioned order shall not be delayed for

                      purpose of or in the name of verification.



                                                  (Dr. Anshuman, J)
Ashwini/-

U      T


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