Created by Fuzzy Cloud

Patna High Court

Dr Sri Ram Kumar Ranjan @ Sri Ram Kumar RajanversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

Holding

The Court granted anticipatory bail to the petitioner, subject to a bond and sureties, finding insufficient grounds to deny bail under the charged offences.

Summary

The petitioner, a practicing doctor and proprietor of Sri Hospital, was implicated in a criminal case (PS Case No. 435 of 2025) alleging that he, along with co‑accused, caused the death of an informant’s father by administering an injection. The petitioner contended that no injection was given, the patient was treated according to medical norms, and the post‑mortem report indicated death due to acute myocardial infarction from coronary atherosclerosis. He also filed a complaint against the informant alleging false accusations and a demand for Rs. 5 lakhs. The State opposed the petition for anticipatory bail, invoking sections 126(2), 115(2), 105, 352, and 3(5) of the Bihar Negotiable Instruments (B.N.S.) Act. The Court, considering the medical evidence, the petitioner’s profession, and lack of intent, granted anticipatory bail subject to a bond of Rs. 10,000 with two sureties and conditions under Section 438(2) of the Cr.P.C. and Section 482(2) of the B.N.S.S.

Issues considered

  • Whether the petitioner is entitled to anticipatory bail in view of the allegations of murder and related offences.
  • Whether Section 105 of the B.N.S. (and other charged sections) are applicable given the lack of intent and medical evidence of natural death.
  • Whether the conditions under Section 438(2) Cr.P.C. and Section 482(2) B.N.S.S. justify granting bail.

Legislation cited

Subjects

  • anticipatory bail
  • medical negligence
  • murder
  • criminal procedure
  • Section 105
  • Section 438
  • doctor
  • post‑mortem report
  • natural death

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.26329 of 2026
                 Arising Out of PS. Case No.-435 Year-2025 Thana- DALSINGHSARAI District- Samastipur
                 ======================================================
                 Dr Sri Ram Kumar Ranjan @ Sri Ram Kumar Rajan S/o Late Raj Deo Singh
                 (Proprietor- Sri Hospital), Resident of Village- Lokathpur Ganj, P.S.-
                 Dalsinghsarai, District- Samastipur, Bihar. Permanent Address- R/o
                 Godhiyari, P.S.- Tajpur, District- Samastipur
                                                                          ... ... Petitioner/s
                                                      Versus
                 The State of Bihar                                ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s    :       Mr. Piyush Kumar Pandey, Advocate
                 For the State           :       Mr. Shyam Kumar Singh, APP
                 ======================================================
                 CORAM: HONOURABLE JUSTICE SMT. SONI SHRIVASTAVA
                                       ORAL ORDER

2   01-05-2026                   Heard learned counsel for the petitioner and learned

                   Additional Public Prosecutor for the State.

                                 2. The petitioner is apprehending his arrest in

                   connection with Dalsinghsarai P.S. Case No. 435 of 2025 in a

                   case registered for the offence punishable under Sections

                   126(2), 115(2), 105, 352, 3(5) of the BNS.

                                 3. As per the prosecution case, the petitioner along

                   with other co-accused persons are said to have killed the

                   informant’s father by administering an injection.

                                 4. Learned counsel for the petitioner submits, at the

                   outset that the petitioner is a practicing doctor and also a

                   proprietor of Sri Hospital, Dalsinghsarai, Samastipur. It is

                   further submitted that the patient was brought in a very serious

                   condition and immediate medical attention was given to him.
Patna High Court CR. MISC. No.26329 of 2026(2) dt.01-05-2026
                                            2/3




          The allegation made in the FIR with regard to an injection being

          administered to the patient by the compounder which led to his

          death, is also incorrect as no injection was administered to him

          and his treatment was being done according to the medical

          norms. It has also been submitted that the postmortem report

          (Annexure-2) also indicates that the patient had coronary artery

          atherosclerosis with calcification and the cause of death opined

          to be acute myocardial infarction due to atherosclerotic coronary

          artery. Learned counsel has also invited this Court’s attention to

          a complaint filed by the petitioner (Annexure-3) against the

          informant and others making an allegation over them of creating

          ruckus in the hospital and also demanding Rs. 5 lakhs for the

          medical negligence. It is, thus, asserted that the petitioner

          neither had any intention nor any knowledge to cause the death

          of the patient, as such, Section 105 of the BNS would not be

          attracted in the facts of the case.

                       5.    Learned APP for the State has opposed the

          application for anticipatory bail.

                       6.    Taking      into     consideration   the   facts   and

          circumstances and also considering the fact that the petitioner is

          a doctor, who was treating the patient, who had died during

          course of treatment, let the above named petitioner, in the event
             Patna High Court CR. MISC. No.26329 of 2026(2) dt.01-05-2026
                                                         3/3




                       of his arrest or surrender before the learned Court below within

                       a period of four weeks from today, be enlarged on bail on

                       furnishing bail bond of Rs.10,000/- (Rupees Ten Thousand) with

                       two sureties of the like amount each to the satisfaction of the

                       learned court below where the case is pending/successor court

                       in connection with Dalsinghsarai P.S. Case No. 435 of 2025,

                       subject to the condition as laid down under Section 438 (2) of

                       the Cr.P.C./482(2) of the B.N.S.S.



                                                 (Soni Shrivastava, J)
priyanka/-

U      T


Continue reading with your account

Sign in to read the full judgment. It’s free.

Sign in to read

Checking your session…

For a signed copy suitable for filing, refer to the court's website.