Patna High Court
Dhiraj Sahni @ Dhirendra Kumar @ Dhirendra SahniversusThe State of Bihar
- Decided
- Disposal
- DISMISSED
- Bench
- SANDEEP KUMAR
Holding
The court held that regular bail could not be granted to the petitioner.
Summary
The petitioner, Dhiraj Sahni, applied for regular bail in a case registered under Section 309(4) of the Bharatiya Nyaya Sanhita, 2023, relating to a robbery of a Bolero pick‑up van. The charge stems from a self‑inculpatory statement of a co‑accused, and the petitioner has been in custody since 21‑Nov‑2024 and faces 18 other serious cases. The trial court had earlier rejected his bail application on 11‑Aug‑2025, citing the gravity of the offence and his criminal antecedents. On a second attempt, the High Court examined the same considerations and found no sufficient ground to relax custody. Consequently, the court declined to grant regular bail, and the application was dismissed.
Issues considered
- Whether bail should be granted to the accused under Section 309(4) of the Bharatiya Nyaya Sanhita, 2023 considering the seriousness of the alleged robbery and the accused's prior criminal record.
Legislation cited
- Bharatiya Nyaya Sanhita, 2023 — s. 309(4)
Subjects
- bail
- criminal procedure
- Section 309
- robbery
- self‑inculpatory statement
- serious offences
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.15807 of 2026
Arising Out of PS. Case No.-125 Year-2024 Thana- SARAI RANJAN District- Samastipur
======================================================
Dhiraj Sahni @ Dhirendra Kumar @ Dhirendra Sahni S/O Harendra Sahni
R/O Village- Sorhatha, P.S- Belsar, Distt.- Vaishali.
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr. Vasant Vikas
For the Opposite Party/s : Mr. Aditya Narayan Singh.1
======================================================
CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
ORAL ORDER
2 24-04-2026 Heard the learned counsel for the petitioner and the
learned APP for the State.
2. This is the 2nd attempt of the petitioner seeking bail
in connection with Sarairanjan P.S. Case No. 125 of 2024
registered for the offence under Section 309(4) of the Bharatiya
Nyaya Sanhita, 2023.
3. Earlier the bail application of the petitioner was
rejected on 11.08.2025 in Cr. Misc. No. 49276 of 2025 which
reads as follows:-
Heard the learned counsel for the petitioner
and learned APP for the State.
2. The petitioner seeks regular bail in
connection with Sarairanjan P.S. Case No. 125 of 2024
registered for the offence under Sections 309(4) of the
Bharatiya Nyaya Sanhita, 2023.
3. Three to four unknown criminals on the
gun point looted the Bolero Pick-up van which was being
driven by the informant. The name of the petitioner has
Patna High Court CR. MISC. No.15807 of 2026(2) dt.24-04-2026
2/2
come during the investigation on the basis of the self-
inculpatory statement of the co-accused namely Arvind
Sahni.
4. The petitioner is in custody since
21.11.2024 and is in accused in 18 more similar and
serious cases.
5. Considering the gravity of the offence
and the criminal antecedents of the petitioner, this
application for regular bail is hereby dismissed.
4. In the case, the charge is to be framed on the next
date of hearing. Considering the gravity of the offence and the
criminal antecedents of the petitioner, I am not inclined to grant
regular bail to the petitioner. Accordingly, this application for
regular bail stands rejected.
(Sandeep Kumar, J)
Shishir/-
U T
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