Patna High Court

Satendra NoneiaversusThe State of Bihar

Decided: 22 January 2026
Disposal: DISPOSED
Bench: SATYAVRAT VERMA

Holding

The Court granted provisional anticipatory bail to the petitioner subject to conditions and verification of his criminal antecedent.

Summary

Satendra Noneia, owner of a Scorpio vehicle, was implicated in a case (PS Nautan Case No. 261 of 2025) for alleged recovery of 666 litres of liquor, alleged under Section 30(a) of the Bihar Excise Act. He contended that the liquor was seized from his vehicle without his knowledge, that he had a clean criminal record, and that his driver acted without his consent. The State opposed his prayer for anticipatory bail. The Court, after considering the submissions, granted provisional anticipatory bail subject to a bail bond of Rs. 500 with two sureties and directed verification of his antecedents by the trial court. If any prior case is found, the bail would not be confirmed; otherwise, the provisional bail would be confirmed.

Issues considered

Whether the petitioner is entitled to anticipatory bail in the case registered under Section 30(a) of the Bihar Excise Act
Whether the ownership of the vehicle used for the alleged offence is sufficient grounds to deny anticipatory bail

Legislation cited

Bihar Negotiable Securities Act (BNSS) — s. 482(2)

Subjects

anticipatory bail
Bihar Excise Act
Section 30(a)
Section 482(2)
vehicle ownership
clean antecedent
seizure of liquor

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.1841 of 2026
                        Arising Out of PS. Case No.-261 Year-2025 Thana- NAUTAN District- Siwan
                 ======================================================
                 Satendra Noneia S/o- Raghunath Noneia S/o- Chitmath, P.S.-Nautan, District-
                 Siwan

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Raghav Prasad, Advocate
                 For the Opposite Party/s :       Md. Anzarul Haque Sahara, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
                                       ORAL ORDER

2   22-01-2026                  1. Heard learned counsel for the petitioner and

                   learned A.P.P. for the State.

                                2. The petitioner apprehends his arrest in a case

                   registered for the offences punishable under Section 30(a) of the

                   Bihar Excise Act.

                                3. Learned counsel for the petitioner submits that

                   petitioner is a person with clean antecedent and allegation is of

                   recovery of 666 liters of liquor from a Scorpio vehicle.

                                4. Learned counsel for the petitioner submits that

                   petitioner was not apprehended from the spot as such nothing

                   was recovered from his conscious possession and he came to be

                   implicated based on the fact that he is owner of the seized

                   vehicle. It is next submitted that no prudent person would use

                   his own vehicle for committing an occurrence and thus would
Patna High Court CR. MISC. No.1841 of 2026(2) dt.22-01-2026
                                            2/3




          create evidence against himself and hence would get implicated,

          it is further submitted that petitioner was completely unaware

          that his driver would misuse the vehicle in the manner as

          alleged.

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

          anticipatory bail of the petitioner.

                       6. Considering the submissions made by the learned

          counsel for the petitioner, the petitioner above-named, in the

          event of his arrest or surrender before the learned Trial Court

          within a period of six weeks from today, be released on

          Provisional anticipatory bail on furnishing bail bonds of Rs.

          500/- (Rupees Five Hundred) with two sureties of the like

          amount each to the satisfaction of the learned Trial Court where

          the case is pending/successor court in connection with Nautan

          P.S. Case No. 261 of 2025 subject to the conditions as laid down

          under Section 482 (2) of the BNSS.

                       7. It is made clear that thereafter the learned Trial

          Court shall verify the criminal antecedent of the petitioner and

          in the event if it is found that petitioner has antecedent of even

          one case then it would be presumed that petitioner, for the

          purposes of seeking anticipatory bail, had concealed his

          antecedent before this Court, as such, the provisional
           Patna High Court CR. MISC. No.1841 of 2026(2) dt.22-01-2026
                                                       3/3




                     anticipatory bail order shall not be confirmed, but after

                     verification if it is found that petitioner is a person with clean

                     antecedent in that event the provisional anticipatory bail order

                     shall be confirmed forthwith.



                                                             (Satyavrat Verma, J)
Sanjay/-

U      T

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