Patna High Court
Dr Sri Ram Kumar Ranjan @ Sri Ram Kumar RajanversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- SONI SHRIVASTAVA
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
- Code of Criminal Procedure, 1973 — s. 438(2)
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
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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
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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
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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
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