Patna High Court

Ranjan Puri @ Ranjan Kumar PuriversusThe State of Bihar

Decided: 16 April 2026
Disposal: BAIL GRANTED
Bench: ANSHUMAN

Holding

The Court granted anticipatory bail to the petitioner subject to a bail bond and conditions under Section 482(2) of the Bhartiya Nyaya Sanhita, 2023.

Summary

The petitioner, Ranjan Puri, sought anticipatory bail fearing arrest in a criminal case (Garkha PS Case No. 865 of 2025) filed under Sections 126(2), 115(2), 109 and 3(5) of the Bhartiya Nyaya Sanhita, 2023. The FIR alleges that the petitioner and two others attacked an informant with an iron rod, causing injury, and fled when by‑standers arrived. The petitioner contended that he is innocent, the dispute stems from a land conflict, and a prior FIR had been lodged by his mother against the informant, suggesting a retaliatory motive. The State opposed bail, stating that a genuine case and a counter‑case exist between the parties. The Court, after considering the circumstances, granted anticipatory bail on the condition of a Rs.30,000 bond and compliance with Section 482(2) of the BNS, 2023.

Issues considered

What is the appropriateness of granting anticipatory bail under the Bhartiya Nyaya Sanhita, 2023 in the present factual matrix?

Legislation cited

Bhartiya Nyaya Sanhita, 2023 — s. 109, 115(2), 126(2), 2(1)(d), 3(5), 482(2)

Subjects

anticipatory bail
criminal procedure
Bhartiya Nyaya Sanhita
Section 126
Section 115
Section 109
Section 3(5)
Section 482
land dispute
false FIR

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.21949 of 2026
                        Arising Out of PS. Case No.-865 Year-2025 Thana- GARKHA District- Saran
                 ======================================================
                 Ranjan Puri @ Ranjan Kumar Puri S/o Sambhu Puri R/o Village - Babhaniya,
                 P.S. - Garkha, District - Saran.
                                                                          ... ... Petitioner/s
                                                  Versus
                 The State of Bihar
                                                                   ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Hemant Kumar, Advocate
                 For the Opposite Party/s :       Mr. Pushpa Sinha.1, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE DR. ANSHUMAN
                                       ORAL ORDER

2   16-04-2026                  Heard learned counsel for the petitioner and learned

                   APP for the State.

                                2. The petitioner is apprehending arrest in connection

                   with Garkha P.S. Case No. 865 of 2025, dated 21.11.2025, lodged

                   under Section 126(2), 115(2), 109 & 3(5) of the Bhartiya Nyaya

                   Sanhita, 2023 (hereinafter referred to as “BNS, 2023”).

                                3. As per the prosecution, FIR has been lodged against

                   three named accused persons, including the present petitioners,

                   alleging that the accused persons attacked the informant

                   repeatedly with an iron rod, due to which he fell down, and when

                   other local persons came at the place of occurrence, the accused

                   persons fled away.

                                4. Learned counsel for the petitioner submits that the

                   petitioner is innocent and has committed no offence. Counsel

                   further submits that the petitioner’s side and the informant’s side

                   are gotiya, and one day prior to the date of this incident, for a land

                   dispute, the mother of the petitioner had lodged an FIR against the
          Patna High Court CR. MISC. No.21949 of 2026(2) dt.16-04-2026
                                                      2/2




                    informant and others, as the informant’s side had already attacked

                    the petitioner’s side. Counsel further submits that when the

                    informant’s side received information that the petitioner’s side had

                    lodged an FIR bearing Garkha P.S. Case No. 864 of 2025 against

                    them, they lodged the present case to save their skin. Counsel also

                    submits that the criminal antecedent of the petitioner is clean.

                                 5. Learned APP for the State opposes the prayer for bail

                    of the petitioner but fairly submits that there is a case and a

                    counter case between the parties.

                                 6. As such, in the present facts and circumstances of

                    this case, let the above named petitioner be released on

                    anticipatory bail, in the event of arrest or surrender before the

                    Trial Court within a period of 4 weeks from today, on furnishing

                    bail bond of Rs.30,000/- (Rupees Thirty Thousand) as mentioned

                    in Section 2(1)(d) of the BNSS, 2023 to the satisfaction of J.M.,

                    1st Class, Saran at Chapra, in connection with Garkha P.S. Case

                    No. 865 of 2025, subject to the conditions as laid down U/s 482(2)

                    of the BNSS, 2023.



                                                                         (Dr. Anshuman, J.)
Aman Kumar/-

U     T

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