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Patna High Court

Dhiraj Sahni @ Dhirendra Kumar @ Dhirendra SahniversusThe State of Bihar

Decided
Disposal
DISMISSED

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

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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