Patna High Court

Rakesh Kumar SahversusThe State of Bihar

Decided: 30 April 2026
Disposal: DISMISSED
Bench: SANDEEP KUMAR

Holding

The court denied bail, holding that the recovery of counterfeit notes justified the refusal of regular bail.

Summary

The petitioner, Rakesh Kumar Sah, was arrested on 27 February 2025 for allegedly possessing counterfeit currency notes worth Rs.12,000. He was charged under sections 179 and 180 of the Bihar Negotiable Instruments Act, 2023, in PS Sonbarsa Case No. 75 of 2025. The petitioner filed a second application for regular bail, arguing that he should be released pending trial. The court examined the fact that the counterfeit notes were recovered from him and considered the seriousness of the offence. Given the nature of the alleged crime and the recovery of the fake notes, the court was not persuaded to grant bail. Consequently, the bail application was rejected, and the petitioner remained in custody.

Issues considered

Whether the petitioner is entitled to regular bail in a case involving possession of counterfeit currency under sections 179 and 180 of the B.N.S. 2023.

Subjects

bail
counterfeit currency
sections 179 and 180
Bihar Negotiable Instruments Act
criminal procedure

Judgment

                       IN THE HIGH COURT OF JUDICATURE AT PATNA
                               CRIMINAL MISCELLANEOUS No.21682 of 2026
                       Arising Out of PS. Case No.-75 Year-2025 Thana- SONBERSA District- Sitamarhi
                  ======================================================
                  Rakesh Kumar Sah S/o- Late Sonelal Sah Resident of Village and P.S.-
                  Kabilashi, Dist- Sarlahi, Nepal
                                                                        ... ... Petitioner/s
                                                  Versus
                  The State of Bihar Bihar
                                                                 ... ... Opposite Party/s
                  ======================================================
                  Appearance :
                  For the Petitioner/s     :       Mr.Ashok Kumar Jha
                  For the Opposite Party/s :       Mr.Pramod Kumar Pandey
                                                   Mr. Shyam Kumar Singh
                  ======================================================
                  CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
                                        ORAL ORDER

2    30-04-2026                  Heard learned counsel for the petitioner and learned

                    counsel for the State.

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

                    of regular bail in connection with Sonbarsa P.S. Case No.75 of

                    2025 registered for the offence punishable under sections 179

                    and 180 of the B.N.S. 2023.

                                 3. The petitioner was arrested while he was in

                    possession of fake currency notes amounting to Rs.12,000/-. He

                    is in custody since 27.02.2025.

                                 4. Considering the recovery of fake currency notes

                    alleged to have been recovered from the petitioner, I am not

                    inclined to grant him bail.

                                 5. Accordingly, this bail application is rejected again.


                                                               (Sandeep Kumar, J)
Vikas/-
U

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