Patna High Court

Satyam KumarversusThe State of Bihar

Decided: 22 April 2026
Disposal: DISPOSED
Bench: SATYAVRAT VERMA

Holding

The Court granted provisional anticipatory bail subject to bond, sureties, and verification of antecedents.

Summary

The petitioner, Satyam Kumar, sought anticipatory bail fearing arrest in a case under Section 30(a) of the Bihar Prohibition and Excise Act, 2022, alleging that 4.5 litres of liquor were recovered from a bag he allegedly threw. He claimed he had a clean antecedent and that the identification by a rapido driver, Ranjit Kumar Pandey, was false and motivated. The State opposed the bail. The Court, after considering the submissions, granted provisional anticipatory bail on the condition of a Rs.500 bond with two sureties and directed the trial court to verify the petitioner’s antecedents. If any prior case is found, the bail will not be confirmed; otherwise, it will be confirmed immediately. The order was made under Section 482(2) of the Criminal Procedure Code.

Issues considered

Whether anticipatory bail should be granted to the petitioner under Section 30(a) of the Bihar Prohibition and Excise Act, 2022.

Legislation cited

Code of Criminal Procedure, 1973 — s. 482(2)

Subjects

anticipatory bail
Section 30
Bihar Prohibition and Excise Act
clean antecedent
identification
false accusation

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.26498 of 2026
                       Arising Out of PS. Case No.-48 Year-2026 Thana- JAKKANPUR District- Patna
                 ======================================================
                 Satyam Kumar S/O Sri Vinod Singh Resident of Vill.- Sakarwar Tola, Ward
                 no.- 15, P.S- Mokama,Dist- Patna
                                                                           ... ... Petitioner/s
                                                  Versus
                 The State of Bihar
                                                                    ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Kumar Manglam
                 For the Opposite Party/s :       Ms. Shaheen Begum
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
                                       ORAL ORDER

2   22-04-2026                  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 offence punishable under Section 30(a) of Bihar

                   Prohibition and Excise Act, 2022.

                                3. Learned counsel for the petitioner submits that

                   petitioner is a person with clean antecedent and allegation is of

                   recovery of 4.5 litres of liquor from a bag thrown by petitioner. It

                   is next submitted that petitioner was not arrested from the spot as

                   such nothing was recovered from his conscious possession and he

                   came to be implicated at the instance of Ranjit Kumar Pandey,

                   who was a rapido driver, who claimed to identify the petitioner but

                   then it is submitted that it appears that Ranjit Kumar Pandey for

                   ulterior reason implicated the petitioner when petitioner admittedly

                   is a person with clean antecedent.
           Patna High Court CR. MISC. No.26498 of 2026(2) dt.22-04-2026
                                                       2/2




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

                     anticipatory bail of the petitioner.

                                  5. Considering the submissions made by the learned

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

                     of his arrest or surrender 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 Jakkanpur

                     P.S. Case No.48/2026, subject to the conditions as laid down under

                     Section 482(2) of the B.N.S.S.

                                  6. It is made clear that the learned trial court thereafter

                     shall verify the criminal antecedents of the petitioner and in the

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

                     in that event, it would be presumed that petitioner had concealed

                     his antecedent before this court, as such, the provisional

                     anticipatory bail order shall not be confirmed but if on verification

                     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)
amit/-
U      T

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