Patna High Court

Naina Chaudhary @ Naina RaniversusThe State of Bihar

Decided: 24 March 2026
Disposal: BAIL GRANTED
Bench: SANDEEP KUMAR

Holding

Bail was granted to the petitioner on the condition of a Rs 10,000 bond with two sureties.

Summary

The petitioner, Naina Chaudhary, sought bail in a case alleging trafficking of minor girls and related offences under multiple statutes. The prosecution alleged that she, along with co‑accused, was involved in bringing minors from other states for exploitation by an orchestra company. The petitioner contended she is a woman falsely implicated, with no specific allegation of sexual assault, no involvement in exploitation, and a clean antecedent, having been in custody since 4 December 2025. The State opposed bail, asserting her participation in the alleged trafficking. Considering the non‑specific nature of the allegations, the petitioner’s gender, clean record, and length of custody, the court ordered her release on bail upon furnishing a bond of Rs 10,000 with two sureties. The bail order was directed to be complied with by the Additional District and Sessions Judge‑Special Judge, POCSO Act, Nalanda.

Issues considered

Whether bail should be granted to the petitioner despite allegations of trafficking and exploitation of minor girls under multiple statutes
Whether the non‑specific nature of allegations and the petitioner’s clean antecedent justify bail

Legislation cited

B.N.S., 2023 — s. 111(4), 143(2), 145, 3(5), 74
Juvenile Justice Act — s. 75, 79
POCSO Act — s. 8

Subjects

bail
trafficking of minors
POCSO
Juvenile Justice
Bonded Labor
gender
clean antecedent

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                               CRIMINAL MISCELLANEOUS No.545 of 2026
                       Arising Out of PS. Case No.-676 Year-2025 Thana- RAJGIR District- Nalanda
                 ======================================================
                 Naina Chaudhary @ Naina Rani D/O Late Pushpendra Chaudhary @ Shyam
                 R/O Mohalla- K.F. 120 Kashiram, Shashtrinagar, P.S.- Lohiyanagar, Dist.-
                 Meruth, U.P.

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr.Vijay Kumar
                 For the Opposite Party/s :       Mr.Madhuri Lata
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
                                       ORAL ORDER

4   24-03-2026                   Heard learned counsel for the petitioner and learned

                   A.P.P. for the State.

                                2. In the present case, the petitioner seeks bail in

                   connection with Rajgir P.S. Case No. 676 of 2025 dated

                   03.12.2025, registered for the offences punishable under

                   Sections 143(2), 145, 74 and 111(4) read with Section 3(5) of

                   the B.N.S., 2023 and Section 8 of the POCSO Act and Sections

                   75 and 79 of the J.J. Act and Sections 16, 17 and 18 of the

                   Bonded Labor System (Abolition) Act.

                                3. As per the prosecution case, petitioner was

                   apprehended with other co-accused persons with allegation of

                   trafficking minor girls and supplying them to some orchestra

                   company where the minor girls were being exploited.
Patna High Court CR. MISC. No.545 of 2026(4) dt.24-03-2026
                                            2/3




                       4. Learned counsel appearing on behalf of the

          petitioner submits that petitioner is a woman and she has falsely

          been implicated in the present case. There is no allegation of

          any sexual assault against the minor girls. The petitioner is not

          engaged in exploitation of minor girls or cruelty against any

          child. In fact, the petitioner has no concern either with the co-

          accused persons or with the orchestra company. The allegation

          are general and vague. Learned counsel lastly submits that

          petitioner is having clean antecedent and she is in custody since

          04.12.2025.

                       5. Learned A.P.P. appearing on behalf of the State

          opposes the submissions made on behalf of the petitioner and

          submits that petitioner and other co-accused persons used to

          bring minor girls from other States.

                       6. Having regard to the facts and circumstances and

          submissions made on behalf of the parties and considering the

          fact that petitioner is woman and further considering the non-

          specific nature of allegation against the petitioner and also

          considering her clean antecedent and her period of custody, the

          petitioner, above-named, is directed to be released on bail, on

          furnishing bail bonds of Rs.10,000/- (Rupees Ten Thousand

          Only) with two sureties of the like amount each to the
          Patna High Court CR. MISC. No.545 of 2026(4) dt.24-03-2026
                                                      3/3




                    satisfaction of learned Additional District and Sessions Judge-

                    VII-cum-Special Judge, POCSO Act, Nalanda at Biharsharif /

                    concerned Court, in connection with POCSO Case No. 215 of

                    2025 / Rajgir P.S. Case No. 676 of 2025.



                                                              (Sandeep Kumar, J)
Vikas/-

U

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