Patna High Court

Vinod RamversusThe State of Bihar

Decided: 4 February 2026
Disposal: BAIL REJECTED
Bench: ANSHUMAN

Holding

The court refused to grant anticipatory bail to the petitioner.

Summary

The petitioner Vinod Ram applied for anticipatory bail under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023, fearing arrest in a case alleging assault, threats with a knife, and causing injury to the informant's daughter. The FIR charges him under multiple sections of the Bhartiya Nyay Sanhita, 2023, including assault and grievous hurt. The petitioner claimed innocence, a clean antecedent, and that the allegations were false, while the State highlighted specific knife‑related assault allegations. The court examined the seriousness of the accusations and the risk of tampering with evidence, and concluded that anticipatory bail was not appropriate. Consequently, the court refused anticipatory bail but directed that if the petitioner surrenders within four weeks, a regular bail application may be heard without prejudice.

Issues considered

Whether anticipatory bail can be granted under Section 482 BNSS, 2023 in view of the alleged assault and knife‑related offences.
Whether the nature of the allegations justifies denial of anticipatory bail.

Legislation cited

Bharatiya Nagarik Suraksha Sanhita, 2023 — s. 482
Bhartiya Nyay Sanhita, 2023 — s. 115(2), 118(1), 126(2), 3(5), 351(2), 351(3), 352

Subjects

anticipatory bail
Section 482
criminal procedure
assault
Bhartiya Nyay Sanhita
high court

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.4924 of 2026
                   Arising Out of PS. Case No.-1094 Year-2025 Thana- AHIYAPUR District- Muzaffarpur
                 ======================================================
                 Vinod Ram Son of Late Mishri Lal Ram Resident of Village- Kolhua Chowk,
                 Garam Chowk Road No. 1, Kolhua Paigambarpur, P.S.- Ahiyapur, District-
                 Muzaffarpur

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Yugal Kishore, Advocate
                 For the Opposite Party/s :       Mr. Awadhesh Kumar Singh, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE DR. ANSHUMAN
                                       ORAL ORDER

2   04-02-2026                      Heard learned Counsel for the petitioner and

                   Learned APP for the State.

                                2. The present criminal miscellaneous application

                   has been filed under Section 482 of the Bharatiya Nagarik

                   Suraksha Sanhita, 2023 (hereinafter referred to as ‘the BNSS,

                   2023’) for grant of anticipatory bail to the petitioner who

                   apprehends arrest in connection with Ahiyapur P.S. Case No.

                   1094 of 2025, lodged on 04.08.2025,                         under Sections

                   126(2)/115(2)/118(1) /352 /351(2)/351(3)/3(5) of the Bhartiya

                   Nyay Sanhita, 2023.

                                3. As per the prosecution, FIR has been lodged

                   against two named accused persons including the present

                   petitioner with allegation that after taking wine he has
Patna High Court CR. MISC. No.4924 of 2026(2) dt.04-02-2026
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          assaulted the informant’s daughter, due to which she became

          unconscious and admitted to hospital. It has also been alleged

          that he was continuously threatening to assault by knife.

                       4. Learned Counsel for the petitioner submits that

          the petitioner is innocent and has committed no offence.

          Counsel submits that antecedent of the petitioner is clean and

          he ready to fulfill all the conditions whatsoever shall be

          imposed upon him. Counsel submits that both informant and

          petitioner’s side are well known to each other. He submits that

          the entire allegation is false. He submits that there were two

          accused persons one of them was granted anticipatory bail at

          the level of Sessions Court itself. Counsel submits that

          allegation of knife is wrong as injury has been caused by hard

          and blunt substance.

                       5. Learned APP for the State opposes the prayer for

          bail of the petitioner and submits that there is specific

          allegation against the petitioner to assault by knife to the

          daughter of the informant.

                       6. In the present facts and circumstances, this Court

          is not inclined to grant anticipatory bail to the petitioner.

          Hence, the prayer for anticipatory bail is hereby refused.

          However, in the event of surrender of the petitioner within
          Patna High Court CR. MISC. No.4924 of 2026(2) dt.04-02-2026
                                                      3/3




                    four weeks from today, the prayer for regular bail shall be

                    considered on the same day without being prejudiced by the

                    order of this Court.



                                                                        (Dr. Anshuman, J)
    Mkr./-

U     T

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