Patna High Court
Santlal @ Santlal UraonversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- RAJESH KUMAR VERMA
Holding
Bail was granted to the petitioner on the condition of a Rs.10,000 bond and compliance with stipulated conditions.
Summary
Santlal Uraon was arrested on 21 July 2025 in connection with a gruesome arson‑murder case where a large mob allegedly tied and set ablaze members of an informant's family. He is charged under multiple sections of the B.N.S. and Sections 3 and 4 of the Prevention of Witch‑Craft Act. The petitioner contended that he has a clean antecedent and that the FIR contains only a generic allegation against him, with no specific act of assault attributed to him. The prosecution opposed bail, but the court noted the absence of a specific charge against the petitioner, his clean record, and the fact that co‑accused had already been granted bail. Consequently, the court ordered his release on bail with a bond of Rs.10,000 and several conditions regarding appearance, non‑tampering with evidence, and verification of antecedents.
Issues considered
- Whether bail should be granted to the petitioner despite the serious nature of the offences alleged.
- Whether the lack of a specific allegation against the petitioner warrants bail.
Legislation cited
- B.N.S. — s. 103(2), 118(1), 118(2), 126(2), 190, 191(2), 191(3), 238
Subjects
- bail
- criminal procedure
- clean antecedent
- arson
- murder
- B.N.S.
- Prevention of Witch Craft Act
- section 190
- section 191
- section 118
- section 126
- section 103
- section 238
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.1811 of 2026
Arising Out of PS. Case No.-169 Year-2025 Thana- MUFFASIL PURNIA District- Purnia
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Santlal @ Santlal Uraon S/o Late Krishna Uraon @ Kishana Uraon R/o
Village - Tetgama (Bhatgama), Ward No. 10, P.S - Mufassil, District - Purnea
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr. N.K. Agrawal, Sr. Advocate
Mr. Kumar Rajdeep, Advocate
Mr. Saroj Kumar Chaudhary, Advocate
Mr. Shivendra Shekhar, Advocate
For the Opposite Party/s : Mr. Anish Chandra, A.P.P.
======================================================
CORAM: HONOURABLE MR. JUSTICE RAJESH KUMAR VERMA
ORAL ORDER
2 19-01-2026 Heard Mr. N. K. Agrawal, learned Senior Counsel for
the petitioner and Mr. Anish Chandra, learned Additional Public
Prosecutor for the State.
2. The petitioner seeks bail, who is in custody since
21.07.2025 in connection with Muffasil P.S. Case No. 169 of
2025, F.I.R. dated 07.07.2025 for the offences punishable under
Sections 190, 191(2), 191(3), 118(1), 118(2), 126(2), 103(2),
238 of the B.N.S. and Section 3/4 of the Prevention of Witch
Craft Act.
3. According to prosecution case, 23 named and 150-
200 unknown persons armed with lathi, danda, iron rod and
Patna High Court CR. MISC. No.1811 of 2026(2) dt.19-01-2026
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arms and ammunition gathered and tied informant's mother,
father, brother, sister-in-law and grandmother with rope and
abused and assaulted them. Thereafter, accused persons dragged
them beside the pond and fuel was sprinkled upon them and
then set ablaze in the night causing their death.
4. Learned senior counsel for the petitioner submits
that petitioner has clean antecedent and he has not committed
any offence as alleged in the F.I.R. From bare perusal of F.I.R.,
it appears that the petitioner is named in the F.I.R. but there is
no specific allegation of any assault or overt act attributed
against the petitioner rather there is general and omnibus
allegation against the petitioner and similarly situated co-
accused persons, namely, Fuliya Devi and Rinkee Devi have
been granted bail by a coordinate Bench of this Hon’ble Court
vide order dated 13.11.2025 passed in Cr. Misc. No. 73138 of
2025. He further submits that the police after investigation,
submitted chargesheet against the petitioner and the petitioner is
in custody since 21.07.2025.
5. Learned APP for the State has vehemently opposed
the prayer for bail of the petitioner.
6. Considering the aforesaid facts and circumstances
and also the fact that the petitioner has clean antecedent, there is
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no specific allegation of any assault or overt act attributed
against the petitioner and similarly situated co-accused persons
have been granted bail by a Coordinate Bench of this Hon’ble
Court, 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
Chief Judicial Magistrate, Purnea in connection with Muffasil
P.S. Case No. 169 of 2025, with the following conditions:
i. Petitioner shall co-operate in the trial and shall be
properly represented on each and every date fixed by the court
and shall remain physically present as directed by the court and
on her absence on two consecutive dates without sufficient
reason, his/her bail bond shall be cancelled by the Court below.
ii. If the petitioner tampers with the evidence or the
witnesses, in that case, the prosecution will be at liberty to move
for cancellation of bail.
iii. And further condition that the court below shall
verify the criminal antecedent of the petitioner and in case at
any stage it is found that the petitioner has concealed his
criminal antecedent, the court below shall take step for
cancellation of bail bond of the petitioner. However, the
acceptance of bail bonds in terms of the above-mentioned order
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shall not be delayed for purpose of or in the name of
verification.
(Rajesh Kumar Verma, J)
Ranjeet/-
U T
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