Patna High Court

Ankit Verma @ AnkitversusThe State of Bihar

Decided: 21 April 2026
Disposal: DISPOSED
Bench: SATYAVRAT VERMA

Holding

Provisional anticipatory bail is granted to the petitioner subject to conditions under Section 482(2) of the BNSS.

Summary

The petitioner, Ankit Verma, sought anticipatory bail after liquor amounting to 97.5 litres was seized from his Hyundai vehicle in a case under Section 30(a) of the Bihar Excise Act. He argued that he had no prior criminal record, was not apprehended at the spot, and had no conscious possession of the liquor, the driver having fled. The State opposed the bail. The Court considered the petitioner’s clean antecedent and lack of direct involvement, and granted provisional anticipatory bail subject to a bail bond of Rs.500 with two sureties and verification of his criminal record within six weeks. If any antecedent is discovered, the bail may be revoked; otherwise, it will be confirmed. The order was made under Section 482(2) of the BNSS.

Issues considered

Whether the petitioner is entitled to anticipatory bail in a case under Section 30(a) of the Bihar Excise Act.
Whether ownership of the vehicle used for the alleged offence suffices to implicate the petitioner.

Legislation cited

BNSS — s. 482(2)

Subjects

anticipatory bail
excise law
seizure of liquor
vehicle ownership
clean antecedent

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.25645 of 2026
                   Arising Out of PS. Case No.-1184 Year-2025 Thana- AHIYAPUR District- Muzaffarpur
                 ======================================================
                 Ankit Verma @ Ankit Son of Narendra kumar Resident of village -
                 Gokulpuri, Ganga Vihar, H. No. D-242, ps- Gokhulpur, Dist- North East
                 Delhi

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Sagar Kumar
                                                  Miss Harsha Shashwat
                 For the Opposite Party/s :       Mr. Arun Kumar
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
                                       ORAL ORDER

2   21-04-2026                   1. Heard learned counsel for the petitioner and

                   learned A.P.P. for the State.

                                 2. The petitioner apprehends his arrest in a case

                   registered for the offences punishable under Section 30(a) of the

                   Bihar Excise Act.

                                 3. Learned counsel for the petitioner submits that

                   petitioner is a person with clean antecedent and allegation is of

                   recovery of 97.5 liters of liquor from a Hyundai car.

                                 4. Learned    counsel for the petitioner submits that

                   petitioner was not apprehended from the spot as such nothing

                   was recovered from his conscious possession and he came to be

                   implicated based on the fact that he is owner of the seized

                   vehicle. It is next submitted that no prudent person would use
Patna High Court CR. MISC. No.25645 of 2026(2) dt.21-04-2026
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          his own vehicle for committing an occurrence and thus would

          create evidence against himself and hence would get implicated,

          it is also submitted that petitioner was completely unaware that

          his driver would misuse the vehicle in the manner as alleged

          who also fled from the spot.

                       5. Learned A.P.P. for the State opposes the prayer for

          anticipatory bail of the petitioner.

                       6. Considering the submissions made by the learned

          counsel for the petitioner, the petitioner above-named, in the

          event of his arrest or surrender before the learned Trial Court

          within a period of six weeks from today, be released on

          Provisional anticipatory bail on furnishing bail bonds of Rs.

          500/- (Rupees Five Hundred) with two sureties of the like

          amount each to the satisfaction of the learned Trial Court where

          the case is pending/successor court in connection with Ahiyapur

          P.S. Case No. 1184 of 2025 subject to the conditions as laid

          down under Section 482 (2) of the BNSS.

                       7. It is made clear that thereafter the learned Trial Court

          shall verify the criminal antecedent of the petitioner and in the

          event if it is found that petitioner has antecedent of even one case

          then it would be presumed that petitioner, for the purposes of

          seeking anticipatory bail, had concealed his antecedent before this

          Court, as such, the provisional anticipatory bail order shall not be
            Patna High Court CR. MISC. No.25645 of 2026(2) dt.21-04-2026
                                                        3/3




                      confirmed, but after verification if it is found that petitioner is a

                      person with clean antecedent in that event the provisional

                      anticipatory bail order shall be confirmed forthwith.



                                                              (Satyavrat Verma, J)
Rishabh/-

U      T

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