Patna High Court

Paras Sah @ Paras Lal SahversusThe State of Bihar

Decided: 6 July 2026
Disposal: BAIL GRANTED
Bench: SATYAVRAT VERMA

Holding

The Court granted anticipatory bail to the petitioner subject to bail bond and surety conditions.

Summary

Paras Sah applied for anticipatory bail after being implicated in offences under Section 317(5) of the Bihar Narcotic Substances Act, 2023, Section 3(4) of the Explosive Substance Act, 1908 and Section 7 of the Essential Commodities Act, 1955. The petitioner claimed a clean antecedent and argued that the informant’s allegation that 4,200 litres of petrol and 1,200 litres of diesel were recovered from a hut belonging to him was false, noting that the hut did not belong to him. The State opposed the bail, contending the seriousness of the offences. The Court considered the petitioner’s clean record, the lack of a proper investigation, and the possibility of surrender within six weeks. It ordered that the petitioner be released on anticipatory bail upon furnishing a bail bond of Rs.10,000 with two sureties, subject to conditions under Section 482(2) of the BNSS. The application was allowed.

Issues considered

Whether anticipatory bail can be granted to the petitioner despite the serious nature of the offences alleged under the BNS Act, Explosive Substance Act and Essential Commodities Act
Whether the petitioner’s clean antecedent and alleged lack of proper investigation justify the grant of anticipatory bail

Legislation cited

Bihar Narcotic Substances Act, 2023 — s. 317(5), 482(2)
Essential Commodities Act, 1955 — s. 7
Explosive Substance Act, 1908 — s. 3(4)

Subjects

anticipatory bail
clean antecedent
false implication
investigation
Bihar Narcotic Substances Act
Explosive Substance Act
Essential Commodities Act
Section 482

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.40639 of 2026
                   Arising Out of PS. Case No.-201 Year-2026 Thana- SUGAULI District- East Champaran
                 ======================================================
                 Paras Sah @ Paras Lal Sah S/o Gyani Sah Resident of Village- Bangara, P.O.-
                 Sugauli, P.S.- Sugauli, District- East Champaran, Bihar-845456

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr.Prashant Raj, Advocate
                 For the Opposite Party/s :       Mr.Bhanu Pratap Singh, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
                                       ORAL ORDER

2   06-07-2026                  1. Heard learned counsel for the petitioner and

                   learned A.P.P. for the State.

                                2. The petitioners apprehend their arrest in a case

                   registered for the offences punishable under Section 317(5)of

                   the BNS, 2023 under Section 3(4) of Explosive Substance Act,

                   1908 and under Section 7 of Essential Commodities Act, 1955.

                                3. Learned counsel for the petitioner submits that

                   petitioner is a person with clean antecedent and the informant

                   alleges that 4,200 liters of petrol along with 1,200 liters of diesel

                   was recovered from a hut and the Chowkidar disclosed that the

                   hut belongs to the petitioner.

                                4. Learned counsel for the petitioner submits that

                   petitioner has been falsely implicated in the instant case by the

                   informant, it is further submitted that a specific ground has been
               Patna High Court CR. MISC. No.40639 of 2026(2) dt.06-07-2026
                                                           2/2




                         taken at Para 7 that the hut does not belong to the petitioner and

                         the police in mechanical manner merely on disclosure of the

                         Chowkidar with whom petitioner is on an inimical term

                         implicated the petitioner in the instant case without holding a

                         proper investigation.

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

                         anticipatory bail application of the petitioner.

                                      6. Considering the submissions and taking into

                         consideration the fact that petitioner is a person with clean

                         antecedent, the 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) with two sureties of the like amount

                         each to the satisfaction of the learned trial court where the case

                         is pending/successor court in connection with Sugauli P.S. Case

                         No. 201 of 2026 subject to the conditions as laid down under

                         Section 482 (2) of the BNSS.

                                      7. The application stands allowed.



                                                   (Satyavrat Verma, J)
Nitesh/-

U          T

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