Patna High Court

Pramanand Chouhan @ Parmanand ChouhanversusThe State of Bihar

Decided: 30 June 2026
Disposal: BAIL GRANTED
Bench: SATYAVRAT VERMA

Holding

Anticipatory bail is granted to the petitioner subject to conditions under Section 482(2) of the BNSS.

Summary

Petitioner Pramanand Chouhan applied for anticipatory bail after being implicated in a FIR alleging assault and land‑related offences. He claimed the allegations were false, arising from a land dispute, and highlighted a four‑day delay in filing the FIR without a satisfactory explanation. The State opposed the bail, arguing the seriousness of the offences listed. The court examined the delay, the vague nature of the allegations, and the possibility of false implication, and concluded that bail could be granted subject to conditions. Accordingly, the court ordered that the petitioner be released on anticipatory bail upon furnishing bail bonds and sureties, subject to Section 482(2) of the BNSS.

Issues considered

Whether anticipatory bail should be granted to the petitioner under the circumstances of alleged false implication and delay in FIR registration.

Legislation cited

Bihar Negotiable Security Act — s. 482(2)
Indian Penal Code — s. 109(1), 115(2), 117(2), 118(1), 126(2), 303(2), 324(3), 329(4), 351(2), 352

Subjects

anticipatory bail
false implication
FIR delay
land dispute
assault
criminal procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.39911 of 2026
                       Arising Out of PS. Case No.-70 Year-2026 Thana- BARAHAT District- Banka
                 ======================================================
                 Pramanand Chouhan @ Parmanand Chouhan S/O- Vishwanath Chouhan
                 Resident of village-Haripur, PS-Barahat, District-Banka

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Sudhir Kumar Mishra
                 For the Opposite Party/s :       Mr. Tarun Prasad Mandal
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
                                       ORAL ORDER

2   30-06-2026                  1.     Heard learned counsel for the petitioner and

                   learned A.P.P. for the State.

                                2. The petitioner apprehend his arrest in a case

                   registered for the offences punishable under Sections 126(2),

                   115(2), 329(4), 109(1), 324(3), 303(2), 117(2), 118(1), 352,

                   351(2), 3/5 of the BNS, 2023.

                                3. Learned counsel for the petitioner submits that

                   petitioner has antecedent of one case and the informant alleges

                   that on 09.03.2026 at 10:00 AM, the accused persons including

                   the petitioner entered her house and started abusing, on

                   objection, all accused assaulted by lathi causing injury on head

                   of her father and also assaulted her mother by lathi injuring her.

                   It is next alleges that Shankar, Rambha Devi, Vishwanath and

                   Divya intend to forcefully capture her land, hence the
Patna High Court CR. MISC. No.39911 of 2026(2) dt.30-06-2026
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          occurrence was committed.

                       4. Learned counsel for the petitioner submits that

          petitioner has been falsely implicated in the instant case by the

          informant. It is next submitted that from perusal of the

          allegations as alleged in the FIR, it would manifest that on

          account of dispute relating to land, the occurrence is alleged to

          have taken place. It is also submitted that the date of occurrence

          is 09.03.2026 and the FIR came to be instituted on 13.03.2026

          i.e. after a delay of more than four days without any plausible

          explanation and even allegation of assault and abuse is not

          specific.

                       5. Learned       A.P.P.     for    the   State   opposes   the

          anticipatory bail application of the petitioner.

                       6. 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 anticipatory bail on furnishing bail

          bonds of Rs. 10,000/- (Rupees Ten Thousand) each with two

          sureties of the like amount to the satisfaction of the learned trial

          court where the case is pending/successor court in connection

          with Barahat P.S. Case No. 70 of 2026 subject to the conditions

          as laid down under Section 482 (2) of the BNSS.
               Patna High Court CR. MISC. No.39911 of 2026(2) dt.30-06-2026
                                                           3/3




                                      7. Accordingly,         the    instant   anticipatory   bail

                         application is allowed.



                                                   (Satyavrat Verma, J)
rajesh/-

U          T

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