Patna High Court

Chetan Yadav @ Monu Yadav @ Kumar ChetanversusThe State of Bihar

Decided: 13 May 2026
Disposal: DISMISSED
Bench: SANDEEP KUMAR

Holding

The Court dismissed the bail application, holding that the large quantity of seized narcotics precludes the grant of regular bail.

Summary

The petitioner, Chetan Yadav, applied for regular bail in a case registered under Sections 8(c) and 21(c) of the Narcotic Drugs and Psychotropic Substances (NDPS) Act, relating to the alleged recovery of 2,158 pieces of codeine‑rich cough syrup, a quantity deemed far above the commercial limit. He had been in custody since 27 February 2026. The prosecution argued that the large quantum indicated a serious offence. The Court considered the statutory provisions and the magnitude of the seizure, concluding that the circumstances did not warrant the grant of bail. Consequently, the bail application was dismissed.

Issues considered

Whether regular bail can be granted in an NDPS case where the seized quantity exceeds the commercial limit
Whether the quantum of codeine recovered justifies denial of bail

Legislation cited

Narcotic Drugs and Psychotropic Substances Act, 1985 — s. 21(c), 8(c)

Subjects

bail
NDPS Act
codeine
quantity of narcotics
commercial limit
regular bail
criminal procedure

Judgment

                       IN THE HIGH COURT OF JUDICATURE AT PATNA
                               CRIMINAL MISCELLANEOUS No.26111 of 2026
                      Arising Out of PS. Case No.-319 Year-2025 Thana- JANKINAGAR District- Purnia
                  ======================================================
                  Chetan Yadav @ Monu Yadav @ Kumar Chetan S/o Dilip Kumar Yadav @
                  Dilip Kumar R/o Village - Charrapatti, Ward No. -12, P.S. - Jankinagar, Dist. -
                  Purnea.
                                                                                ... ... Petitioner/s
                                                    Versus
                  The State of Bihar Bihar
                                                                         ... ... Opposite Party/s
                  ======================================================
                  Appearance :
                  For the Petitioner/s     :       Mr.Deepak Kumar
                  For the Opposite Party/s :       Mr.Ram Anurag Singh
                  ======================================================
                  CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
                                        ORAL ORDER

3    13-05-2026                    Heard the parties.

                                 2. The petitioner seeks regular bail in connection with

                    Special Jankinagar P.S. Case No. 319 of 2025 registered for the

                    offence under Sections 8(c), 21(c) of the NDPS Act.

                                 3. As per the prosecution case, the recovery is of 2158

                    pieces of codeine rich cough syrup.

                                 4. The petitioner is in custody since 27.02.2026.

                                 5. In view of the quantum of recovery of codeine,

                    which is much more than the commercial quantity, this Court is

                    not inclined to grant bail to the petitioner.

                                 6. Accordingly, this application stands dismissed.



                                                             (Sandeep Kumar, J)
Vikas/-

U

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