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Patna High Court

Satyam Kumar @ Angad Kumar @ AngadversusThe State of Bihar

Decided
Disposal
DISMISSED

Holding

The Court denied bail to the petitioner, finding the allegations and his criminal antecedents sufficient to refuse regular bail.

Summary

The petitioner, Satyam Kumar, was arrested in connection with a case (PS Narhia Case No. 106/2023) alleging offences under several sections of the B.N.S. and Section 27 of the Arms Act. The prosecution alleges that the petitioner and others, while attempting to obtain a discount on cigarettes, assaulted an informant and fired at his ear. The petitioner contended that he was falsely implicated, highlighted that he has five prior criminal records, and has been in custody since 25‑11‑2025, offering to cooperate with the trial. The State, represented by the Additional Public Prosecutor, opposed regular bail. Considering the seriousness of the alleged offences and the petitioner’s criminal antecedents, the Court declined to grant bail. Consequently, the bail application was dismissed.

Issues considered

  • Whether bail should be granted to the petitioner despite the serious nature of the offences alleged under the B.N.S. and the Arms Act.
  • Whether the petitioner’s claim of false implication and his willingness to cooperate affect the bail decision.

Legislation cited

  • Arms Act — s. 27
  • B.N.S. — s. 109(1), 115(2), 126(2), 303(2), 329(4), 3(5), 351(2), 352

Subjects

  • bail
  • criminal antecedent
  • assault
  • firearms
  • Arms Act
  • false implication
  • section 27
  • B.N.S.

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.22107 of 2026
                      Arising Out of PS. Case No.-106 Year-2025 Thana- Narhiya District- Madhubani
                 ======================================================
                 Satyam Kumar @ Angad Kumar @ Angad Son of Vinod Kumar Roy @
                 Vinod Rai Resident of Village- Jhitaki @ Jhitki, P.S.- Narahia, District-
                 Madhubani

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr.Jitendra Kumar Bharti, Advocate
                 For the Opposite Party/s :       Mr.Sanjay Kumar Tiwary, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
                                       ORAL ORDER

2   08-04-2026                     Heard learned counsel for the petitioner and learned

                   Additional Public Prosecutor for the State.

                                2. The petitioner seeks bail in connection with Narhia

                   P.S. Case No. 106/2023 registered for the offences punishable

                   under Sections 126(2), 115(2), 109(1), 303(2), 329(4), 352,

                   351(2) and 3(5) of B.N.S. and Section 27 of Arms Act.

                                3. As per the prosecution case, petitioner and others

                   had gone to purchase cigarettes, they wanted a discount of Rs.

                   one on purchase of the cigarette and when the informant

                   refused, they assaulted the informant and fired on his ear.

                                4. Learned counsel for the petitioner submits that

                   petitioner has falsely been implicated in the case. Learned

                   counsel further submits that he has five criminal antecedents
              Patna High Court CR. MISC. No.22107 of 2026(2) dt.08-04-2026
                                                          2/2




                        and he is in custody since 25.11.2025. The petitioner undertakes

                        to co-operate in the case/ trial.

                                     5. Learned APP for the State has opposed the prayer

                        for regular bail of the petitioner..

                                     6. Considering the allegation levelled against the

                        petitioner and the criminal antecedent, this Court is not inclined

                        to grant bail to the petitioner.

                                     7. Accordingly, this application stands dismissed.



                                                   (Sandeep Kumar, J)
tusharika/-

U       T


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