Patna High Court

Subodh YadavversusThe State of Bihar

Decided: 27 April 2026
Disposal: BAIL REJECTED
Bench: SATYAVRAT VERMA

Holding

Anticipatory bail was denied as the allegations of assault causing grievous injury were deemed serious and the investigation was ongoing.

Summary

The petitioner, Subodh Yadav, applied for anticipatory bail after being implicated in a case (PS. Case No.308 of 2025) alleging assault and other offences under the B.N.S., 2023. He claims a clean record and asserts that the allegations stem from a dispute over video‑recording a religious puja, during which he was allegedly accused of assaulting the informant. The State opposed the bail, highlighting specific allegations of assault causing a grievous injury to the informant's nasal bone and noting that the investigation is ongoing. The court examined the seriousness of the charges, the nature of the alleged injury, and the fact that the petitioner was directly implicated. Concluding that the allegations were serious and the investigation was pending, the court declined to grant anticipatory bail. Consequently, the petition for anticipatory bail was rejected.

Issues considered

Whether the petitioner is entitled to anticipatory bail in view of the alleged assault and grievous injury.
Whether the seriousness of the charges and ongoing investigation preclude the grant of anticipatory bail.

Legislation cited

B.N.S., 2023 — s. 109, 115(2), 126(2), 303(2), 3(5), 351(2), 351(3), 352

Subjects

anticipatory bail
assault
grievous injury
criminal procedure
false implication
investigation

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.16522 of 2026
                     Arising Out of PS. Case No.-308 Year-2025 Thana- SAHEBPUR KAMAL District-
                                                        Begusarai
                 ======================================================
                 Subodh Yadav S/o Late Bijul Yadav Resident of village- Bahloriya, ward no.
                 9, P.S.- Sahebpur Kamal, District- Begusarai
                                                                            ... ... Petitioner/s
                                                     Versus
                 The State of Bihar
                                                                     ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr. Sarvottam Kumar
                 For the Opposite Party/s :      Mr. Anil Prasad Singh
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
                                       ORAL ORDER

3   27-04-2026                  1. Heard learned counsel for the petitioner and learned

                   A.P.P. for the State.

                                2. The petitioner apprehends his arrest in conneciton

                   with Sahebpur Kamal P.S. Case No.308 of 2025, registered for the

                   offences punishable under Sections 126(2), 115(2), 109, 303(2),

                   351(2), 351(3), 352 and 3(5) of the B.N.S., 2023.

                                3. Learned counsel for the petitioner submits that

                   petitioner is a person with clean antecedent and the informant

                   alleges that he along with Rajan had gone to see Goddess Kali

                   Puja on 20.10.2025 at 8 P.M. and Rajan started video-graphing the

                   occasion, which was objected by Sanjiv and when they refused,

                   the named accused persons assaulted them and informant suffered

                   injury on head on account of assault by rod by petitioner and the

                   accused persons also snatched his mobile and locket.

                                4. Learned counsel for the petitioner submits that

                   petitioner has been falsely implicated in the instant case by the
           Patna High Court CR. MISC. No.16522 of 2026(3) dt.27-04-2026
                                                       2/2




                     informant. It is next submitted that from perusal of the allegation

                     as alleged in the FIR, it would manifest that on account of dispute

                     relating to video-graphing the occasion of Puja, the occurrence is

                     alleged to have taken place. It is further submitted that no doubt

                     petitioner is alleged to have assaulted the informant causing injury

                     on head but then from perusal of the allegation as alleged in the

                     FIR, it would manifest that informant also alleges that all accused

                     persons assaulted him.

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

                     prayer for anticipatory bail of the petitioner and submits that there

                     is specific allegation against this petitioner of assaulting the

                     informant and the injury on nasal bone has been opined to be

                     grievous in nature which is a vital part of the body and

                     investigation is continuing.

                                  6. Considering the submissions made by the learned

                     APP, the Court is not inclined to extend the privilege of

                     anticipatory bail to the petitioner.

                                  7. The anticipatory bail application of the petitioner is

                     rejected.



                                               (Satyavrat Verma, J)
amit/-
U      T

Continue reading with your account

Checking your session…