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Patna High Court

Satya Narayan SahniversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

Holding

The court granted bail to the petitioner.

Summary

Satya Narayan Sahni was arrested in connection with a case involving multiple offences under the Indian Penal Code (sections 341, 323, 307, 447, 448, 504, 506, 34 and later 302) and section 27 of the Arms Act, alleged to have fired on a victim who died after eleven months. He had been in custody since 10 December 2025 and claimed he was falsely implicated, asserting that the primary accusation of firing rested on another accused, Lal Babu Sahni, and noting that co‑accused Krishna Kumar had already been granted bail. The petitioner’s counsel argued for his release on bail, emphasizing his innocence and lack of flight risk. The High Court considered the bail application and, without expressing any view on the merits of the underlying case, ordered his release on a bail bond of Rs. 10,000 with two sureties of equal amount. The order was limited to the bail matter and does not prejudice any future trial proceedings.

Issues considered

  • Whether the petitioner is entitled to bail despite the seriousness of the offences, including murder (Section 302 IPC).
  • Whether the addition of Section 302 IPC alters the bail considerations.

Legislation cited

Subjects

  • bail
  • Indian Penal Code
  • Arms Act
  • murder
  • attempted murder
  • assault
  • criminal intimidation
  • pre‑trial detention
  • criminal procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.17097 of 2026
                    Arising Out of PS. Case No.-12 Year-2024 Thana- BIBHUTIPUR District- Samastipur
                 ======================================================
                 Satya Narayan Sahni S/o Raj Kumar Sahni R/o Village - Patpara North, P.S.-
                 Bibhutipur, District- Samastipur

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr.Dilip Kumar Roy
                 For the Opposite Party/s :       Mr.Ramchandra Sahni
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
                                       ORAL ORDER

2   24-04-2026                    Heard learned counsel for the petitioner and learned

                   APP for the State.

                                   2. The petitioner seeks bail in connection with

                   Bibhutipur P.S. Case No. 12 of 2024 registered for the offence

                   under Sections 341, 323, 307, 447, 448, 504, 506, 34 of the

                   Indian Penal Code and 27 of the Arms Act. Later Section 302 of

                   the Indian Penal Code was also added.

                                   3. As per the prosecution case, the petitioner and

                   others are said to have fired upon the victim who died after 11

                   months from the date of alleged occurrence.

                                   4. The petitioner is in jail since 10.12.2025.

                                   5. Learned counsel for the petitioner submits that

                   the petitioner is innocent and has falsely been implicated in this

                   case. He further submits that the the co-accused Krishna Kumar
          Patna High Court CR. MISC. No.17097 of 2026(2) dt.24-04-2026
                                                      2/2




                    and one other co-accused has already been granted bail. He next

                    submits that the main allegation of firing is against one Lal

                    Babu Sahni.

                                    6. Considering the aforesaid facts, this application

                    is allowed.

                                    7. Let the petitioner, above named, be released on

                    bail on furnishing bail bond of Rs. 10,000/- (Ten Thousand)

                    with two sureties of the like amount each to the satisfaction of

                    the learned concerned Court below in connection with

                    Bibhutipur P.S. Case No. 12 of 2024.

                                    8. It is, however, clarified that the observations

                    made herein are limited to the adjudication of the present bail

                    application and shall not prejudice the case of the petitioner at

                    any subsequent stage of the trial and this Court has not

                    expressed any opinion on the merits of the case.



                                                               (Sandeep Kumar, J)
Vikas/-

U


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