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Patna High Court

Sadanand SahversusThe State of Bihar

Decided
Disposal
DISMISSED

Holding

The petition for regular bail was dismissed, and the earlier denial of bail was upheld.

Summary

The petitioner, Sadanand Sah, sought regular bail for offences including murder, attempt to murder, rioting, assault, and illegal possession of arms arising from a 2023 case. The trial court had earlier denied bail, citing his involvement in multiple serious crimes and his criminal antecedents. The petitioner argued that the trial was nearing its conclusion, warranting bail. The High Court considered the gravity of the charges, the petitioner’s history of multiple pending cases, and the fact that he had been in custody since August 2023. Concluding that the seriousness of the offences and his criminal record outweighed the argument of trial proximity, the Court refused to review its earlier order and dismissed the bail application.

Issues considered

  • Whether the petitioner is entitled to regular bail despite serious charges under the IPC and Arms Act
  • Whether the proximity of trial conclusion justifies granting bail

Legislation cited

Subjects

  • bail
  • criminal procedure
  • IPC offences
  • Arms Act
  • trial pending

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.44118 of 2025
                         Arising Out of PS. Case No.-141 Year-2023 Thana- JADIA District- Supaul
                 ======================================================
                 Sadanand Sah S/O Lakhan Sah @ Dalo Sah Resident of Village- Khoont,
                 P.S.- Jadiya, District- Supaul.

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :        Ms. Patla Kumari, Advocate
                 For the State            :        Ms. Nirmala Kumari, APP
                 For the Informant        :        Ms. Meena Singh, Advocate
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
                                       ORAL ORDER

3   10-02-2026                   Heard learned counsel for the petitioner as well as

                   informant and learned APP for the State.

                                 2. This is the second attempt on behalf of the

                   petitioner for grant of bail in connection with S.T. No. 231 of

                   2024 arising out of Jadiya P.S. Case No. 141 of 2023 registered

                   for the offence under Section 147, 148, 149, 341, 323, 324, 307,

                   120(B), 504, 506 of the IPC and Section 27 of the Arms Act.

                                 3. Earlier, the bail application of the petitioner has

                   been rejected by this Court vide order dated 21.03.2024 passed

                   in Cr. Misc. No. 4848 of 2024, which reads as under:

                                                 Heard learned counsel for the petitioner
                                    and learned APP for the State.
                                                 2. This application for grant of regular bail
                                    arises out of Jadiya P.S. Case No.141 of 2023
                                    registered for the offence punishable under sections
             Patna High Court CR. MISC. No.44118 of 2025(3) dt.10-02-2026
                                                         2/2




                                       147, 148, 149, 341, 323, 324, 307, 120- B, 504 and 506
                                       of the Indian Penal Code.
                                                    3. The petitioner is said to have shot at the
                                       victim causing stomach injury.
                                                    4. The petitioner is in custody since
                                       06.08.2023. He is accused in seven more criminal
                                       cases.
                                                    5. Considering the criminal antecedents of
                                       the petitioner, I am not inclined to grant the petitioner
                                       privilege of regular bail. Accordingly, this bail
                                       application is rejected. The trial court is directed to
                                       expedite the trial of all the cases pending against the
                                       petitioner and conclude the same as early as possible.


                                   4. The trial is on the verge of its conclusion.

                                    5. Considering the above facts and circumstances, I

                       am not inclined to review my earlier order..

                                    6. Accordingly, this application is dismissed.



                                                  (Sandeep Kumar, J)
priyanka/-

U      T


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