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Patna High Court

Manish KumarversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

Holding

The court granted bail to the petitioner on condition of furnishing a bond and complying with stipulated conditions.

Summary

Manish Kumar was arrested on 11‑12‑2025 in connection with an FIR alleging his assistance in forging documents to cheat in a state examination, invoking several sections of the Bihar Negotiable Instruments Act and Section 10 of the Bihar Conduct of Examination Act, 1981. He applied for bail, claiming a clean antecedent and arguing that the allegations were fabricated, noting that a co‑accused, Ranjit Kumar, had already been granted bail by a coordinate bench. The State opposed the bail. The court considered the petitioner’s clean record, the precedent of bail to the similarly situated co‑accused, and the lack of substantive evidence beyond suspicion. It ordered that bail be granted upon furnishing a bond of Rs.10,000 with two sureties and imposed conditions regarding cooperation, non‑tampering with evidence, and verification of antecedents. The bail bond was to be accepted without delay for verification purposes.

Issues considered

  • Whether the petitioner is entitled to bail despite the serious charges under the Bihar Negotiable Instruments Act and the Bihar Conduct of Examination Act.
  • Whether the grant of bail to a similarly situated co‑accused mandates bail for the petitioner.
  • Whether the petitioner’s clean antecedent and the alleged lack of substantive evidence justify bail.

Legislation cited

Subjects

  • bail
  • criminal procedure
  • examination fraud
  • forged documents
  • clean antecedent
  • conditions of bail

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.22537 of 2026
                  Arising Out of PS. Case No.-334 Year-2025 Thana- MITHANPURA District- Muzaffarpur
                 ======================================================
                 Manish Kumar S/O Dukhan Singh Resident of Village- Mithanpura, P.S. and
                 Dist.- Muzaffarpur, Permanent Add. Vill.- Bhanwar Bigha, P.O.- Sohraiya,
                 PS- Parasbigha, Dist.- Jehanabad.

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr.Sanjay Kumar Sinha, Advocate
                 For the Opposite Party/s :      Mr.Bhanu Pratap Singh, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE RAJESH KUMAR VERMA
                                       ORAL ORDER

2   07-04-2026                  Heard Mr.Sanjay Kumar Sinha, learned counsel

                   for the petitioner and Mr.Bhanu Pratap Singh,                         learned

                   A.P.P. for the State.

                                2. The petitioner seeks bail, who is in custody

                   since 11.12.2025 in connection with Mithanpura P.S. Case

                   No. 334 of 2025, F.I.R. dated 10.12.2025 registered for the

                   offence punishable under Sections 318(4), 338, 336(3),

                   340(2), 61(2), 3(5) of BNS and Section 10 of Bihar Conduct

                   of Examination Act, 1981.

                                3. Allegation against the petitioner is assisting in

                   the act of creating forged documents to procure undue

                   advantage to co-accused.
Patna High Court CR. MISC. No.22537 of 2026(2) dt.07-04-2026
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                       4. Learned counsel appearing for the petitioner

          submits that the petitioner has clean antecedent. As per

          allegation in the FIR, one Santosh Kumar has been

          apprehended at the examination centre and he has admitted

          that he has appeared in the examination on behalf of Ranjit

          Kumar and Ranjit Kumar has admitted that the petitioner

          has assisted in the act of cheating in the examination in

          question. Learned counsel for the petitioner submits that the

          the allegation as alleged in the FIR is false and fabricated

          and the petitioner has not committed any offence as alleged

          in the FIR and the petitioner has been made accused in the

          present case merely on the basis of suspicion and similarly

          situated co-accused person, namely, Ranjit Kumar @

          Ranjeet Kumar has been granted bail by a Coordinate

          Bench of this Hon’ble Court vide order dated 12.03.2026

          passed in Cr. Misc. No.14203 of 2026 and the police, after

          investigation, submitted chargesheet against the petitioner

          and the petitioner is in custody since 11.12.2025.

                       5. Learned APP for the State has opposed the

          prayer for bail of the petitioner.

                       6. Considering the aforesaid fact, petitioner has
Patna High Court CR. MISC. No.22537 of 2026(2) dt.07-04-2026
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          clean antecedent and similarly situated co-accused person

          has been granted bail by a Coordinate Bench of this

          Hon’ble Court, let the petitioner, above named, be released

          on bail on furnishing bail bond of Rs.10,000/- (Ten

          Thousand) with two sureties of the like amount each to the

          satisfaction of learned Judicial Magistrate, F.C., Court No.-

          17, Muzaffarpur in connection with Mithanpura P.S. Case

          No. 334 of 2025, with the following conditions:-

                       (I) Petitioner shall co-operate in the trial and shall

          be properly represented on each and every date fixed by the

          Court and shall remain physically present as directed by the

          Court and on his/her absence on two consecutive dates

          without sufficient reason, his/her bail bond shall be

          cancelled by the Court below.

                       (II) If the petitioner tampers with the evidence or

          the witnesses, in that case, the prosecution will be at liberty

          to move for cancellation of bail.

                       (III) And, further condition that the court below

          shall verify the criminal antecedent of the petitioner and in

          case at any stage, it is found that the petitioner has

          concealed his criminal antecedent, the court below shall
               Patna High Court CR. MISC. No.22537 of 2026(2) dt.07-04-2026
                                                           4/4




                         take step for cancellation of bail bond of the petitioner.

                         However, the acceptance of bail bonds in terms of the

                         above-mentioned order shall not be delayed for purpose of

                         or in the name of verification.



                                                (Rajesh Kumar Verma, J)
Nitesh/-

U          T


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