Patna High Court

Rangita Devi @ Sangita DeviversusThe State of Bihar

Decided: 19 January 2026
Disposal: BAIL GRANTED
Bench: R P MISHRA

Holding

The Court granted anticipatory bail to the petitioner subject to the conditions prescribed under Section 482(2) of the Bharatiya Nagarika Suraksha Sanhita, 2023.

Summary

Rangita Devi (also known as Sangita Devi) sought anticipatory bail fearing arrest in a case (Garkha PS Case No. 379 of 2025) under Section 30(a) of the Bihar Prohibition and Excise Act, where 60 litres of liquor was allegedly recovered. The prosecution’s case is based on the recovery of liquor from a public place, while the petitioner contends that her name was implicated solely on the confessional statement of a co‑accused and that she had no knowledge of the liquor. She also argued that there is no prima facie case, she has no criminal antecedent, and the investigation failed to comply with Section 103 of the Bharatiya Nagarika Suraksha Sanhita, 2023. The State opposed the bail. The Court, after considering the submissions, granted anticipatory bail on the condition that the petitioner surrenders within six weeks, furnishes a bail bond of Rs. 15,000 with two sureties, and complies with the conditions of Section 482(2) of the Bharatiya Nagarika Suraksha Sanhita, 2023.

Issues considered

Whether anticipatory bail should be granted to the petitioner under the circumstances.
Whether the prosecution has made out a prima facie case under Section 30(a) of the Bihar Prohibition and Excise Act.
Whether the investigation complied with Section 103 of the Bharatiya Nagarika Suraksha Sanhita, 2023.

Legislation cited

Bharatiya Nagarika Suraksha Sanhita, 2023 — s. 103, 482(2)

Subjects

anticipatory bail
Bihar Prohibition and Excise Act
Bharatiya Nagarika Suraksha Sanhita
Section 30(a)
Section 103
Section 482(2)
false implication
confessional statement
bail conditions

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.3577 of 2026
                        Arising Out of PS. Case No.-379 Year-2025 Thana- GARKHA District- Saran
                 ======================================================
                 Rangita Devi @ Sangita Devi W/o- Pawan Nut Village- Pith Ghat PS- Garkha
                 Dist- Saran Chapra

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Nalin Kumar, Advocate
                 For the Opposite Party/s :       Ms. Sangeeta Sharma, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE RUDRA PRAKASH
                 MISHRA
                                       ORAL ORDER

2   19-01-2026                  Heard learned counsel for the petitioner and learned

                   APP for the State.

                               2. The petitioner apprehends his arrest in connection

                   with Garkha P.S. Case No. 379 of 2025 instituted for the

                   offences punishable under Section 30(a) of the Bihar Prohibition

                   and Excise Act.

                               3. The prosecution case, in short, is that total 60 litres

                   of liquor was recovered from plastic jar.

                               4. Learned counsel for the petitioner submitted that the

                   petitioner has falsely been implicated in the present case. The

                   name of the petitioner transpired in this case on the basis of

                   confessional statement of the apprehended co-accused. Learned

                   counsel further submitted that petitioner has no knowledge and
           Patna High Court CR. MISC. No.3577 of 2026(2) dt.19-01-2026
                                                       2/2




                     concern with the alleged recovery. Learned counsel further

                     submitted that the alleged recovery has been made from an open

                     place which is accessible to public at large. Learned counsel ,

                     therefore, submitted that prima-facie, no case is made out

                     against the petitioner. The petitioner has no criminal antecedent.

                     There is no compliance of Section 103 of the Bharatiya

                     Nagarika Suraksha Sanhita, 2023.

                                5. Learned APP for the State has vehemently opposed

                     the prayer for grant of bail to the petitioner.

                                  6. Considering the aforesaid facts and circumstances

                     of the case, let the petitioner, above named, in the event of

                     arrest/surrender before the lower court within a period of six

                     weeks from today, be released on anticipatory bail on furnishing

                     bail bonds of Rs. 15,000/- ( Rupees Fifteen Thousand) with two

                     sureties of the like amount each to the satisfaction of Court

                     below/concerned Court in connection with Garkha P.S. Case

                     No. 379 of 2025, subject to the conditions as laid down under

                     Section 482(2) of the Bharatiya Nagarika Suraksha Sanhita,

                     2023.



                                           (Rudra Prakash Mishra, J)
Alok Verma/-

U      T

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