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Patna High Court

Krishna Kumar YadavversusThe State of Bihar

Decided
Disposal
DISMISSED

Holding

The Court held that regular bail could not be granted to the petitioners.

Summary

The petitioners, Krishna Kumar Yadav and Dharmanath Kumar, were arrested for allegedly operating a CSP centre and preparing fake government documents using forged digital signatures, seals, and QR codes, thereby cheating the public and the government. They were charged under Sections 318(4), 338, 336(3), 340(2), 341(1) and 3(5) of the Bharatiya Nyaya Sanhita, 2023, and have been in custody since 26 March 2026. The petitioners applied for regular bail, arguing that they were entitled to liberty pending trial. The Court examined the seriousness of the offences, the material evidence linking the accused to the crime, and the potential risk to public interest. Considering the nature of the allegations and the available evidence, the Court declined to grant regular bail. The bail application was therefore rejected, with the Court noting that its observations were prima facie and not a determination on the merits of the case.

Issues considered

  • Whether regular bail should be granted to the accused under the Bharatiya Nyaya Sanhita for offences involving forgery of government documents and digital signatures.

Legislation cited

Subjects

  • regular bail
  • forgery
  • digital signatures
  • cyber crime
  • Bharatiya Nyaya Sanhita
  • criminal procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.40496 of 2026
                   Arising Out of PS. Case No.-145 Year-2026 Thana- RAXAUL District- East Champaran
                 ======================================================
           1.     Krishna Kumar Yadav S/o Late Babunand Rai Resident of village - Siswa,
                  Ward No 03, P.S.- Raxaul, District- East Champaran
           2.    Dharmanath Kumar S/o Sadhu Patel R/o vill - Bhelahi, P.S.- Bhelahi, Distt.-
                 East Champaran

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Ajay Kumar Singh
                 For the Opposite Party/s :       Mr. Jharkhandi Upadhyay
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
                                       ORAL ORDER

2   23-06-2026                  Heard the learned counsel for the petitioners and

                   learned APP for the State.

                                2. The petitioners seek regular bail in connection with

                   Raxaul P.S. Case No. 145 of 2026 registered for the offence

                   under Sections 318(4), 338, 336(3), 340(2), 341(1) and 3(5) of

                   the Bharatiya Nyaya Sanhita, 2023.

                                3. As per the prosecution case, it is alleged that the

                   petitioners were operating a CSP centre and were preparing fake

                   government documents by using forged digital signatures, seals

                   and QR codes of government officers, thereby cheating both the

                   public and the government system.

                                4. The petitioners are in custody since 26.03.2026.
            Patna High Court CR. MISC. No.40496 of 2026(2) dt.23-06-2026
                                                        2/2




                      During investigation, sufficient materials have come to connect

                      the petitioners with the crime.

                                   5. Considering the nature of allegation and the

                      materials available on record, this Court is not inclined to grant

                      regular bail to the petitioners.

                                   6. Accordingly, this application for regular bail stands

                      rejected.

                                   7. It is made clear that any observation made herein is

                      prima facie in nature and limited solely for the purpose of

                      adjudication of the present bail application. Such observations

                      shall not be construed as an expression on the merits of the case

                      and shall not influence the trial or any other proceedings in any

                      manner.



                                                         (Sandeep Kumar, J)
Shishir/-

U       T


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