Patna High Court

Krishan Kumar @ Krishna KumarversusThe State of Bihar

Decided: 24 March 2026
Disposal: DISMISSED
Bench: SANDEEP KUMAR

Holding

Bail was not granted; the application was dismissed.

Summary

Krishan Kumar was arrested on 21 July 2025 in connection with a FIR lodged by the deceased’s wife, alleging that the petitioner was hired to conspire and cause her death. The investigation revealed that the informant had engaged the petitioner’s services and plotted the murder. The petitioner applied for bail before the Patna High Court under Section 103(1) of the BNS, 2023. The court examined the seriousness of the alleged conspiracy, the nature of the offence and the risk of evidence tampering. Finding the allegations grave, the court declined to grant bail and dismissed the application.

Issues considered

Whether bail should be granted to the petitioner under Section 103(1) of the BNS, 2023 given the alleged conspiracy and murder.

Legislation cited

BNS, 2023 — s. 103(1)

Subjects

bail
criminal procedure
high court
Bihar
Section 103(1)
conspiracy
murder

Judgment

                       IN THE HIGH COURT OF JUDICATURE AT PATNA
                                CRIMINAL MISCELLANEOUS No.534 of 2026
                   Arising Out of PS. Case No.-805 Year-2025 Thana- SAHARSA SADAR District- Saharsa
                  ======================================================
                  Krishan Kumar @ Krishna Kumar Son of Late Kamo Sharma Resident of
                  Village - Dhakjari Ward No. 12, P.S. - Sonbarsa Kachahary, District - Saharsa.
                                                                               ... ... Petitioner/s
                                                     Versus
                  The State of Bihar Bihar
                                                                        ... ... Opposite Party/s
                  ======================================================
                  Appearance :
                  For the Petitioner/s     :      Mr.Amarnath Jha
                  For the Opposite Party/s :      Mr.Md. Iftekhar Mahmood
                  ======================================================
                  CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
                                        ORAL ORDER

4    24-03-2026                    Heard the parties.

                                 2. The petitioner seeks bail in connection with

                    Saharsa Sadar P.S. Case No. 805 of 2025 registered for the

                    offence under Section 103(1) of the BNS, 2023.

                                  3. The petitioner is in custody since 21.07.2025.

                                 4. The informant is the wife of the deceased and she

                    had lodged the FIR against unknown criminals and subsequently

                    during investigation, it has come that the informant had engaged

                    the service of the petitioner and after hatching conspiracy had

                    got killed her.

                                 5. Considering the aforesaid facts, this Court is not

                    inclined to grant bail tot he petitioner.

                                 6. Accordingly, this application is dismissed.


                                                             (Sandeep Kumar, J)
Vikas/-
U

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