Patna High Court

Dhiraj Sahni @ Dhirendra Kumar @ Dhirendra SahniversusThe State of Bihar

Decided: 24 April 2026
Disposal: DISMISSED
Bench: SANDEEP KUMAR

Holding

The application for regular bail is dismissed, and the petitioner remains in custody.

Summary

The petitioner, Dhiraj Sahni, applied for regular bail for a case registered under Section 111 of the BNS and Sections 25(1‑B)(a), 26 and 35 of the Arms Act. His earlier bail application had been rejected on 11‑08‑2025. The court noted that the petitioner was caught planning a loot, with a pistol and a live cartridge recovered, and has been in custody since 13‑11‑2024. He is also implicated in seventeen other serious cases. Considering the seriousness of the allegations and his criminal antecedents, the court declined to revisit its earlier order and dismissed the bail application. Consequently, the petitioner remains in custody.

Issues considered

Whether regular bail should be granted to the petitioner despite the serious nature of the offences and his multiple pending cases.

Legislation cited

Arms Act — s. 25(1‑B)(a), 26, 35
Bihar Negotiable Instruments Act — s. 111

Subjects

regular bail
criminal procedure
Arms Act
repeat offender
high court

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.17168 of 2026
                   Arising Out of PS. Case No.-860 Year-2024 Thana- HAJIPUR SADAR District- Vaishali
                 ======================================================
                 Dhiraj Sahni @ Dhirendra Kumar @ Dhirendra Sahni Son of Harendra Sahni
                 R/o Village - Sorhatha, P.S. - Belsar, District - Vaishali.

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

                                2. This is the second attempt of the petitioner for grant

                   of regular bail in connection with Hajipur Sadar P.S. Case No.

                   860 of 2024 registered for the offence under Section 111 of the

                   BNS and under Sections 25(1-B)(a), 26, 35 of the Arms Act.

                                3. Earlier the bail application of the petitioner was

                   rejected vide order dated 11.08.2025 passed in Cr. Misc. No.

                   49141 of 2025.

                                4. The petitioner and others were caught planning a

                   loot. One country made pistol and one live cartridge has been

                   recovered from the petitioner.

                                5. The petitioner is in custody since 13.11.2024 and he

                   is accused in 17 more cases of similar and serious in nature.

                                6. Considering the antecedents of the petitioner and
          Patna High Court CR. MISC. No.17168 of 2026(2) dt.24-04-2026
                                                      2/2




                    the nature of allegation levelled against the petitioner, this Court

                    is not inclined to review its earlier order.

                                 7. Accordingly, this application is dismissed.



                                                               (Sandeep Kumar, J)
Vikas/-

U

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