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Patna High Court

Md. Iqbal HussainversusThe State of Bihar

Decided
Disposal
DISMISSED

Holding

The court denied regular bail to the petitioner.

Summary

The petitioner, Md Iqbal Hussain, was arrested on 18 January 2025 for alleged involvement in trafficking children from Bihar to Punjab and Haryana. He is charged under Section 143(6) of the Bharatiya Nyaya Sanhita, 2023, Section 79 of the Juvenile Justice Act, and Section ¾ of the C.A.L. (P & R) Act. The petitioner applied for regular bail, arguing that some witnesses had already been examined and he had been in custody for several months. The High Court considered the seriousness of the human‑trafficking allegations and the statutory provisions that restrict bail in such cases. The court declined to revisit its earlier order and rejected the bail application, directing that the trial be expedited.

Issues considered

  • Whether regular bail should be granted to a person accused of child trafficking under the Bharatiya Nyaya Sanhita, Juvenile Justice Act and C.A.L. (P & R) Act.

Legislation cited

Subjects

  • bail
  • human trafficking
  • child trafficking
  • criminal procedure
  • Bharatiya Nyaya Sanhita
  • Juvenile Justice Act
  • C.A.L. (P & R) Act
  • Patna High Court

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.17185 of 2026
                   Arising Out of PS. Case No.-10 Year-2025 Thana- MUZAFFARPUR RAIL P.S. District-
                                                          Saran
                 ======================================================
                 Md. Iqbal Hussain S/o- Md. Mansoor Alam R/v- Rajgaon ward no 3 Ps-
                 Barari Dist- Katihar

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr.Sunil Kumar Pandey
                 For the Opposite Party/s :      Mr.Rajendra Singh
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
                                       ORAL ORDER

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

                   learned APP for the State.

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

                   of regular bail in connection with Muzaffarpur Rail P.S. Case

                   No. 10 of 2025 registered for the offence under Sections 143(6)

                   of the Bharatiya Nyaya Sanhita, 2023, under Section 79 of the

                   JJ Act and ¾ of the C.A.L.(P & R) Act.

                                3. This is a case of human trafficking. The petitioner

                   was found involved in trafficking children to Punjab and

                   Haryana. He has been arrested along with the children.

                                4. The petitioner is in custody since 18.01.2025 and

                   in the trial, some witnesses have already been examined.

                                5. Considering the aforesaid facts and circumstances,
          Patna High Court CR. MISC. No.17185 of 2026(2) dt.24-04-2026
                                                      2/2




                    I am not inclined to review my earlier order.

                                 6. Accordingly, this application for regular bail is

                    hereby rejected.

                                 7. The trial of the petitioner is directed to be

                    expedited.



                                                               (Sandeep Kumar, J)
Vikas/-

U


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