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Patna High Court

Ravindra ChauhanversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

Holding

Anticipatory bail is granted to the petitioner subject to bond, sureties and conditions of cooperation, with the power to cancel if the petitioner fails to cooperate.

Summary

The petitioner, Ravindra Chauhan, feared arrest in a case registered under Sections 191(2), 191(3), 190, 103(1), 61(2), 352 and 351(3) of the BNS, 2023, alleging involvement in the assault and death of the informant's husband. He argued that he is not named in the FIR and that his alleged connection stems solely from a co‑accused's confession made in police custody, which lacks evidentiary value, and that he has a clean antecedent. Citing a prior decision granting anticipatory bail to a similarly situated accused, Vatuk, the petitioner sought anticipatory bail. The State opposed the relief but could not refute the precedent. The Court, after considering the submissions, granted anticipatory bail subject to a bond of Rs.10,000 with two sureties and conditioned it on the petitioner’s cooperation with the investigation, reserving the right of the trial court to cancel the bail if cooperation lapses.

Issues considered

  • Whether anticipatory bail should be granted to the petitioner in the absence of direct evidence linking him to the offences.
  • Whether the precedent of granting anticipatory bail in the Vatuk case is applicable to the present petition.

Subjects

  • anticipatory bail
  • Section 482 CrPC
  • confession in custody
  • clean antecedent
  • bail conditions
  • criminal procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.4728 of 2026
                    Arising Out of PS. Case No.-177 Year-2025 Thana- NAGARNAUSA District- Nalanda
                 ======================================================
                 Ravindra Chauhan S/o Indal Chauhan R/o Vill - Chhotkilodipur, P.S -
                 Nagarnausa, Dist - Nalanda

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr. Birendra Kumar, Advocate
                 For the Opposite Party/s :      Mr. Ram Sumiran Rai, APP
                 For the Informant        :      Mr. Ranjit Kumar Thakur, Advocate
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
                                       ORAL ORDER

2   19-03-2026                  1. Heard learned counsel for the petitioner, learned

                   A.P.P. for the State and the learned counsel appearing on behalf

                   of the informant.

                                2. The petitioner apprehends his arrest in a case

                   registered for the offences punishable under Sections 191(2),

                   191(3), 190, 103(1), 61(2), 352 and 351(3) of the BNS, 2023.

                                3. Learned counsel for the petitioner submits that

                   petitioner is a person with clean antecedent and in sum and

                   substance the allegation as alleged in the FIR is that the accused

                   persons assaulted the husband of the informant leading to his

                   death.

                                4. Learned counsel for the petitioner submits that

                   petitioner is not named in the FIR and his name transpired in the
Patna High Court CR. MISC. No.4728 of 2026(2) dt.19-03-2026
                                            2/3




          case during the course of investigation based on confession of

          co-accused Sudama in police custody which does not have any

          evidentiary value. It is further submitted that during the course

          of investigation apart from confession, no material transpired

          connecting the petitioner with the offence even remotely. It is

          next submitted that Vatuk had approached this Court seeking

          anticipatory bail by filing Criminal Miscellaneous No. 4426 of

          2026 and the same came to be allowed by an order dated

          04.02.2026 by a learned Co-ordinate Bench, it is also submitted

          that case of the petitioner is similar to the case of Vatuk, thus,

          seeks anticipatory bail for the petitioner based on parity. It is

          also submitted that if privilege of anticipatory bail is granted,

          the petitioner will not abscond rather will cooperate in the

          investigation to prove his innocence.

                       5. Learned A.P.P. for the State as well as the learned

          counsel appearing on behalf of the informant opposes the

          anticipatory bail application of the petitioner, but then are not in

          a position to rebut the submissions of the learned counsel

          appearing on behalf of the petitioner that Vatuk has been granted

          the privilege of anticipatory bail by a learned Co-ordinate

          Bench.

                       6. Considering the submissions made by the learned
            Patna High Court CR. MISC. No.4728 of 2026(2) dt.19-03-2026
                                                        3/3




                      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) 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 Nagarnausa P.S. Case No. 177 of 2025 subject to the

                      conditions as laid down under Section 482 (2) of BNSS.

                                   7. However, it is made clear that in the event if the

                      Investigating Officer of the case files an application before the

                      learned Trial Court bringing to its notice that petitioner despite

                      giving assurance to this Court is not co-operating in the

                      investigation, in that event the learned Trial Court shall be at

                      liberty to cancel the bail bonds of the petitioner.

                                   8. Let a copy of this order be sent to the concerned

                      police station through the learned Trial Court.

                                   9. Accordingly,         the    instant   anticipatory   bail

                      application stands allowed.



                                                              (Satyavrat Verma, J)
Rishabh/-

U      T


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