Patna High Court

Manish Kumar SinghversusThe State of Bihar

Decided: 27 January 2026
Disposal: BAIL GRANTED
Bench: R P MISHRA

Holding

The court held that bail should be granted to the petitioner.

Summary

The petitioner, Manish Kumar Singh, applied for bail in a robbery case (Section 392 IPC) where four unknown accused allegedly robbed a bank of Rs. 11,57,078 and mobiles. The petitioner contends he was falsely implicated, as his name appears only through a co‑accused’s confessional statement and no incriminating material was found on him. He has been in custody since 26‑09‑2025 and has three prior criminal antecedents. The State opposed bail, but the court noted the lack of direct evidence against the petitioner and the non‑compliance with Section 103 of the Bharatiya Nagarik Suraksha Sanhita, 2023. Consequently, the court granted bail on a bond of Rs. 15,000 with two sureties.

Issues considered

Whether the petitioner is entitled to bail despite being implicated solely through a co‑accused’s confession.
Whether the provisions of Section 103 of the Bharatiya Nagarik Suraksha Sanhita, 2023, have been complied with.
Whether the petitioner’s prior criminal antecedents preclude the grant of bail.

Legislation cited

Bharatiya Nagarik Suraksha Sanhita, 2023 — s. 103
Indian Penal Code — s. 392

Subjects

bail
robbery
Section 392 IPC
confessional statement
co‑accused
Section 103
Bharatiya Nagarik Suraksha Sanhita
criminal antecedents

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.2581 of 2026
                       Arising Out of PS. Case No.-271 Year-2023 Thana- DUMRA District- Sitamarhi
                 ======================================================
                 Manish Kumar Singh S/o- Madhurendra Singh Village- Narha PS- Suppi
                 Distt- Sitamarhi
                                                                       ... ... Petitioner/s
                                              Versus
                 The State of Bihar Bihar
                                                                ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :        Mr.Ritesh Kumar Narain Singh, Advocate
                 For the Opposite Party/s :        Mr.Sucheta Yadav, A.P.P.
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE RUDRA PRAKASH
                 MISHRA
                                       ORAL ORDER

2   27-01-2026                  Heard learned counsel for the petitioner and learned

                   APP for the State.

                               2. The petitioner seeks bail in connection with Dumra

                   P.S. Case No. 271 of 2023, instituted for the offences under

                   Sections 392 of the Indian Penal Code.

                               3. Prosecution case, in short, is that four unknown

                   accused persons entered into the Bandhan Bank and on the point

                   of pistol they robbed cash of Rs. 11,57,078/- along with three

                   tabs and Vivo company mobiles.

                               4. Learned counsel for the petitioner submitted that the

                   petitioner has falsely been implicated in the present case.

                   Charge-Sheet has been submitted in this case. Petitioner is not

                   named in the F.I.R. The name of the petitioner transpired in this

                   case on the basis of confessional statement of the co-accused

                   Amrendra Kumar @ Nishant. No incriminating/looted article

                   has been recovered from the conscious possession of the
           Patna High Court CR. MISC. No.2581 of 2026(2) dt.27-01-2026
                                                       2/2




                     petitioner, rather, the same has been recovered from the house of

                     co-accused Satyaprakash @ Prakash, Ranjan Kumar and

                     Amrendra Kumar. It has been submitted on behalf of the

                     petitioner that the petitioner is in custody since 26.09.2025 and

                     has three criminal antecedents. Learned counsel for the

                     petitioner further submits that other co-accused has been granted

                     bail by a Co-ordinate Bench of this Court vide order dated

                     10.01.2024 passed in Cr. Misc. No. 66627 of 2023. There is no

                     compliance of Section 103 of the Bharatiya Nagarik Suraksha

                     Sanhita, 2023.

                                 5. Learned A.P.P. for the State has vehemently

                     opposed the prayer for grant of bail to the petitioner.

                                  6. Considering the aforesaid facts and circumstances

                     of the case, as also the period of custody undergone by the

                     petitioner, this Court is inclined to grant bail to the petitioner.

                                  7. Let the petitioner be released on bail on furnishing

                     bail bonds of Rs. 15,000/- ( Rupees Fifteen Thousand) with two

                     sureties of the like amount each to the satisfaction of Court

                     below/concerned Court in connection with Dumra P.S. Case

                     No. 271 of 2023.


                                           (Rudra Prakash Mishra, J)
manish/-
U      T

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