Patna High Court

Kamdev Paswan @ Ranjeet PaswanversusThe State of Bihar

Decided: 1 May 2026
Disposal: BAIL REJECTED
Bench: ANIL KUMAR SINHA

Holding

The court denied anticipatory bail, holding that the petitioner’s involvement as indicated in the co‑accused’s confessional statements and the gravity of the offences warranted rejection of the application.

Summary

The petitioner, Kamdev Paswan, filed a second anticipatory bail application fearing arrest in a murder case (IPC §§302, 201, 34) arising from the death of Khushi Kumari. The FIR alleged that the petitioner’s son, Dewvrat Paswan, and another co‑accused murdered the victim and that the petitioner’s name appeared in the confessional statements of the co‑accused. The petitioner argued that there was no direct or circumstantial evidence against him and that he was being made a scapegoat. The court noted the seriousness of the offences and the fact that the petitioner’s name was disclosed during investigation, which could further substantiate the case. Having already rejected the first anticipatory bail application and finding no new material or change in circumstances, the court dismissed the second anticipatory bail plea.

Issues considered

Whether anticipatory bail can be granted when the only evidence against the petitioner is the confessional statements of co‑accused.
Whether a second anticipatory bail application can be entertained in the absence of any new material or change in circumstances.

Legislation cited

Indian Penal Code — s. 201, 302, 34

Subjects

anticipatory bail
murder
confessional statement
IPC
criminal procedure
bail jurisprudence

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                             CRIMINAL MISCELLANEOUS No.27820 of 2026
                       Arising Out of PS. Case No.-105 Year-2024 Thana- ALOULI District- Khagaria
                 ======================================================
                 Kamdev Paswan @ Ranjeet Paswan Son of Lt. Sukhdev Paswan R/O Vill.-
                 Kehuna Sumbha, P.S.- Bahadurpur O.P. (Alauli), Distt.- Khagaria

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s            :        Mr.Pankaj Kumar
                 For the Opposite Party/s        :        Mr.Mohammed Arif
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ANIL KUMAR SINHA
                                       ORAL ORDER

2   01-05-2026                  1. Heard the parties.

                                2. This is second anticipatory bail application on

                   behalf of the petitioner who apprehends his arrest in connection

                   with Alauli P.S. Case No.105 / 2024 corresponding to G.R. No.

                   788 / 2024 dated 19.03.2024 registered for the offence under

                   Section 302, 201, 34 of the I.P.C.

                                3. As per the F.I.R. on 17.03.2024 at about 6:00 A.M.

                   the informant came to know through mobile that his sister

                   -Khushi Kumari went missing. During search, the informant got

                   to know that dead body of a girl has been found floating in the

                   river. The informant and his family members went to identify

                   the body. The body was having the part below the neck and

                   above the stomach. From the bangles and tattoo marks, it was

                   identified as the body of the victim Khushi Kumari. The
Patna High Court CR. MISC. No.27820 of 2026(2) dt.01-05-2026
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          informant alleged that his sister was in love with the co-accused

          Dewvrat Paswan. The informant has further alleged that all the

          accused persons have murdered his sister and threw her dead

          body in the river. The name of the petitioner has surfaced during

          investigation in the confessional statement of the co-accused /

          Niraj Mukhiya and Dewvrat Paswan.

                       4. Learned counsel for the petitioner submits that

          except confessional statement of the co-accused, there is no

          direct or circumstantial evidence against the petitioner. He

          further submits that being the father of the co-accused namely

          Dewvrat Paswan, the petitioner has been made scape -goat in

          this case. He next submits that in the trial before the court below

          six witnesses have been examined but none of the witnesses has

          supported the prosecution against the petitioner.

                       5. After taking into consideration the gravity of the

          offence and the fact that name of the petitioner has been

          disclosed by the co-accused during the course of investigation

          which may be the basis of further investigation against the

          petitioner, this court earlier rejected the prayer for anticipatory

          bail on the merit of the case.

                       6. Again, a second anticipatory bail application has

          been filed and learned counsel for the petitioner tried to re-argue
               Patna High Court CR. MISC. No.27820 of 2026(2) dt.01-05-2026
                                                           3/3




                         the matter. I do not find any merit or subsequent event for

                         consideration of anticipatory bail application filed for the

                         second time. Accordingly, the same is rejected.



                                                  (Anil Kumar Sinha, J)
praful/-

U          T

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