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Patna High Court

Ram Niranjan Kumar @ Mangal SinghversusThe State of Bihar

Decided
Disposal
BAIL REJECTED

Holding

The bail petition is dismissed as there is no new ground to revisit the earlier decision.

Summary

Ram Niranjan Kumar was arrested in connection with offences under Sections 103(1) and 3(5) of the Bharatiya Nyaya Sanhita, 2023 and Section 27 of the Arms Act. He has been in judicial custody since 18 February 2025 and this is his second application for regular bail after the court rejected his earlier petition on merit. The petitioner argued that only a charge has been framed, no witness has been examined, and the trial is unlikely to conclude soon, warranting bail. The State opposed bail, emphasizing the serious allegation of firing and noting that the earlier rejection already considered the merits. The court found no new ground to revisit the earlier decision, rejected the bail application, and directed the lower court to expedite the trial within six months, allowing the petitioner to renew his bail plea thereafter.

Issues considered

  • Whether the petitioner is entitled to bail despite the trial not having progressed beyond charge framing
  • Whether the earlier denial of bail on merit precludes a fresh bail application without new grounds
  • Whether the seriousness of the offences under the Bharatiya Nyaya Sanhita and the Arms Act justifies continued detention

Legislation cited

Subjects

  • bail
  • judicial custody
  • trial delay
  • Arms Act
  • Bharatiya Nyaya Sanhita
  • criminal procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.19104 of 2026
                   Arising Out of PS. Case No.-606 Year-2024 Thana- LAKHISARAI District- Lakhisarai
                 ======================================================
                 Ram Niranjan Kumar @ Mangal Singh S/o Lalan Singh @ Lalo Singh R/o
                 Vill- Walipur, PS- Piparia, District- Lakhisarai

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Ramakant Sharma, Sr. Advocate
                                                  Mr. Mayank Raj, Advocate
                 For the Opposite Party/s :       Mr. Ajay Kumar Jha, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE RUDRA PRAKASH
                 MISHRA
                                       ORAL ORDER

2   03-04-2026              Heard learned counsel for the petitioner and learned APP

                   for the State.

                            2.      The petitioner seeks bail in connection with

                   Lakhisarai P.S. Case No. 606 of 2024 instituted for the offences

                   under Sections 103(1) & 3(5) of the Bharatiya Nyaya Sanhita,

                   2023 and Section 27 of the Arms Act.

                            3.      This is the second attempt of the petitioner for bail.

                   The petitioner has renewed his prayer for grant of regular bail

                   which was earlier rejected on merit by this Court vide order

                   dated 29.07.2025 passed in Cr. Misc. No. 46379 of 2025.

                            4.      Learned counsel for the petitioner submits that the

                   petitioner is languishing in judicial custody since 18.02.2025

                   without any rhymes or reason. Learned counsel for the
           Patna High Court CR. MISC. No.19104 of 2026(2) dt.03-04-2026
                                                       2/2




                     petitioner mainly submits that till date only charge is framed in

                     this case and no witness has been examined. Learned counsel

                     for the petitioner submits that there is no likelihood of the trial

                     being concluded in the near future, hence, petitioner may be

                     enlarged on bail.

                              5.     Learned APP for the State opposes the prayer for

                     grant of bail. It is fervently submitted that there is direct

                     allegation of firing against the petitioner, which is mentioned in

                     earlier rejection order, hence, petitioner does not deserve the

                     privilege of bail.

                              7.     There is no new ground to consider the bail petition

                     of the petitioner, which is already decided by this Court on

                     merit.

                              8.     In view of the above, the prayer for bail of the

                     petitioner is again rejected with a direction to the court below to

                     expedite the trial and conclude the same expeditiously

                     preferably within a period of six months from today. If the trial

                     is not concluded within the period of six months, as stated

                     above, the petitioner will be at liberty to renew his prayer before

                     the court below.


                                                                 (Rudra Prakash Mishra, J)
Raj Kishore/-
U      T


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