Patna High Court

Satyendra Kumar Mahto @ Munshi Jee @ Satyendra Kumar @ Sahendra KumarversusThe State of Bihar

Decided: 19 February 2026
Disposal: BAIL GRANTED
Bench: PRABHAT KUMAR SINGH

Holding

The court held that anticipatory bail must be granted as there is no documentary evidence and the petitioner has a clean antecedent.

Summary

The petitioner, Satyendra Kumar Mahto, was implicated in a case under Section 308(2) of the Bharatiya Nyaya Sanhita for allegedly demanding ransom from an informant. The FIR alleges two separate demands of Rs.2,000 and Rs.25,000, but no documentary evidence (such as a chit) supports the allegations. The petitioner contended that he is innocent, has a clean antecedent, and was falsely implicated due to village politics. The State opposed the bail application. The court, noting the absence of any written proof and the petitioner’s clean record, granted anticipatory bail, directing that if arrested within eight weeks he may be released on a bail bond of Rs.10,000 with two sureties, subject to conditions under Section 482(2) of the Bharatiya Nagarik Suraksha Sanhita.

Issues considered

Whether anticipatory bail should be granted in the absence of documentary evidence supporting the allegations under Section 308(2).
Whether the alleged offence under Section 308(2) is bailable given the petitioner’s clean antecedent.
Whether the conditions imposed under Section 482(2) of the Bharatiya Nagarik Suraksha Sanhita are appropriate for the grant of anticipatory bail.

Legislation cited

Bharatiya Nagarik Suraksha Sanhita — s. 482(2)
Bharatiya Nyaya Sanhita — s. 308(2)

Subjects

anticipatory bail
ransom demand
Section 308
Section 482
clean antecedent
lack of evidence
criminal law
bail conditions

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.4285 of 2026
                         Arising Out of PS. Case No.-182 Year-2025 Thana- KARPI District- Arwal
                 ======================================================
                 Satyendra Kumar Mahto @ Munshi Jee @ Satyendra Kumar @ Sahendra
                 Kumar Son of Amar singh @ Khesari Mahto Resident at village- Mali P.S-
                 Banshi, District -Arwal

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Ramakant Singh, Advocate
                 For the Opposite Party/s :       Mr. Lalan Kumar, A.P.P.
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                       ORAL ORDER

2   19-02-2026                   Heard learned counsel for the petitioner and the State.

                                2. Petitioner apprehends arrest in a case registered for

                   the offence punishable under Section 308(2) of the Bharatiya

                   Nyaya Sanhita.

                                3. As per F.I.R., this petitioner is alleged to have

                   demanded ransom of Rs. 2,000/- out of Rs. 5,000/- which was

                   deposited in the account of informant by the labour department.

                   It is further alleged that earlier also, this petitioner took Rs.

                   25,000/- from the informant out of Rs. 50,000/- which had been

                   given to informant under Kanya Vivah Yojana.

                                4. Learned counsel for the petitioner submits that

                   petitioner is innocent and has committed no offence. Petitioner

                   is co-villager of the informant and has falsely been implicated in
              Patna High Court CR. MISC. No.4285 of 2026(2) dt.19-02-2026
                                                          2/2




                        this case due to village politics. There is no chit of paper in

                        substantiate the allegation levelled against petitioner. Petitioner

                        claims clean antecedent.

                                     5. Learned A.P.P. for the State vehemently opposed

                        the bail application.

                                     6. Considering the fact that there is no chit of paper to

                        support the allegation and clean antecedent of the petitioner, this

                        anticipatory bail is allowed and it is ordered that let the above

                        named petitioner in the event of his arrest/surrender before the

                        court below within a period of eight weeks from today, be

                        enlarged on bail on furnishing bail-bond of Rs. 10,000/- (ten

                        thousand) with two sureties of the like amount each to the

                        satisfaction of Chief Judicial Magistrate, Arwal in connection

                        with Karpi P. S. Case No. 182 of 2025, subject to condition as

                        laid down under Section 482(2) of the Bharatiya Nagarik

                        Suraksha Sanhita, 2023.



                                              (Prabhat Kumar Singh, J)
Navya/-

U         T

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