Patna High Court

Satyendra YadavversusThe State of Bihar

Decided: 23 February 2026
Disposal: BAIL GRANTED
Bench: KHATIM REZA

Holding

The Court held that regular bail should be granted to the petitioners.

Summary

Petitioners Satyendra Yadav and Rajesh Yadav were arrested in connection with an assault case (PS No. 89 of 2025) alleging grievous injury to an informant's mother and a lesser assault on the informant. They claimed innocence, asserting the matter stemmed from a prior case filed by the petitioner’s daughter and that both parties had sustained injuries. The petitioners, in judicial custody since 17-11-2025, have no prior criminal record and a charge‑sheet has already been filed. The State opposed regular bail, but the Court considered the nature of the allegations, the existence of a charge‑sheet, the length of custody, and the petitioners' clean antecedents. Consequently, the Court granted regular bail on the condition of a Rs.10,000 bond with two sureties each.

Issues considered

Whether regular bail should be granted to the petitioners under the Bharatiya Nyaya Sanhita, 2023 in view of the charges of assault and grievous injury.

Legislation cited

Bharatiya Nyaya Sanhita, 2023 — s. 109, 115(2), 126(2), 303(2), 333, 3(5), 351(2), 352, 74

Subjects

regular bail
criminal procedure
assault
grievous injury
charge-sheet
judicial custody
clean antecedents

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.2779 of 2026
                 Arising Out of PS. Case No.-89 Year-2025 Thana- BARABAR TOURIST District- Jehanabad
                 ======================================================
           1.     Satyendra Yadav S/O Late Guru Sahay Yadav R/O Villag- Mishir Bigha, P.S-
                  Barabar Tourism (Vishunganj), Distt.- Jehanabad (Bihar).
           2.    Rajesh Yadav S/o Late Suryadev Yadav @ Surajdeo Yadav R/O Village-
                 Mishir Bigha, P.S- Barabar Tourism (Vishunganj), Distt.- Jehanabad (Bihar).

                                                                                 ... ... Petitioner/s
                                                       Versus
                 The State of Bihar

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr.Uday Kumar, Advocate
                 For the Opposite Party/s :      Mr.Dr. Ajeet Kumar, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE KHATIM REZA
                                       ORAL ORDER

3   23-02-2026                  Heard learned counsel for the petitioners and learned

                   A.P.P. for the State.

                                2. The petitioners seek regular bail in Barabar

                   Tourism (Vishunganj)             P.S. Case No. 89 of 2025 dated

                   17.08.2025, registered under Sections 126(2), 115(2), 333,

                   303(2), 109, 74, 352, 351(2) and 3(5) of the Bharatiya Nyaya

                   Sanhita, 2023.

                                3. As per the FIR, petitioner no.1, Satyendra Yadav, is

                   alleged to have assaulted the informant’s mother on the head

                   with an iron rod, causing grievous injury as a consequence of

                   which she became unconscious whereas, the petitioner no.2 is

                   alleged only to have pushed the informant after catching hold of
Patna High Court CR. MISC. No.2779 of 2026(3) dt.23-02-2026
                                            2/3




          her hair.

                       4. Learned counsel for the petitioners submits that the

          petitioners are innocent and they have been falsely implicated in

          the present case. It is submitted that the dispute has arisen out of

          a case and counter-case bearing Barabar Tourism (Vishunganj)

          P.S. Case No. 91 of 2025 which has been lodged by the daughter

          of petitioner no.1. Both sides are co-villagers and next-door

          neighbours. It is further submitted that the petitioners’ side has

          also sustained injuries in the same occurrence, though the

          injuries on the prosecution side are stated to be grievous in

          nature. Learned counsel further submits that charge-sheet has

          already been submitted in the case. Lastly, it is submitted that

          the petitioners are in judicial custody since 17.11.2025 and have

          no criminal antecedents.

                       5. Learned Additional Public Prosecutor for the State

          has vehemently opposed the prayer.

                       6. Taking into account the nature of allegations, the

          case and counter-case arising out of the same occurrence,

          submission of the charge-sheet, period of custody as also the

          fact that petitioners have clean antecedents, this Court is

          inclined to grant bail to the petitioners.

                       7. Let the petitioners be released on bail upon
           Patna High Court CR. MISC. No.2779 of 2026(3) dt.23-02-2026
                                                       3/3




                     furnishing bail bonds of Rs.10,000/- (ten thousand) each with

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

                     learned Court of Judicial Magistrate 1st class, Jehanabad or

                     successor      Court      in     connection         with   Barabar   Tourism

                     (Vishunganj) P. S. Case No. 89 of 2025.

                                  8. The application stands allowed.



                                                    (Khatim Reza, J)
shyambihari/-

U      T

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