Patna High Court

Sadre Alam @ Md. Sadre AlamversusThe State of Bihar

Decided: 19 January 2026
Disposal: DISMISSED
Bench: NAWNEET KUMAR PANDEY

Holding

The petitioner does not deserve bail and the bail application is rejected.

Summary

Sadre Alam was arrested at Thawe railway station on 7 March 2025 after police recovered mobile phones, stolen personal items and 54 intoxicated tablets, alleging that he and co‑accused drugged travelers’ tea or food to steal their belongings. The petitioner claims he was merely transiting from Lucknow to Muzaffarpur and was falsely implicated, asserting innocence and denying any involvement with the recovered items. The State contends that the petitioner has five prior criminal convictions and that the seized tablets and stolen articles link him to the alleged offences under Sections 317(4) and 317(5) of the BNS and Sections 20 and 22 of the NDPS Act. The court examined the seriousness of the accusations, the presence of substantial material evidence, and the petitioner’s criminal antecedents. Considering the gravity of the allegations and the risk of tampering with evidence, the court held that the petitioner does not merit regular bail. Consequently, the bail application was rejected.

Issues considered

Whether the petitioner is entitled to regular bail in view of the offences under Sections 317(4) and 317(5) of the BNS and Sections 20/22 of the NDPS Act
Whether the petitioner’s prior criminal antecedents and the seized narcotic tablets justify denial of bail

Legislation cited

BNS — s. 317(4), 317(5)
N.D.P.S. Act — s. 20, 22

Subjects

regular bail
NDPS Act
BNS
drug trafficking
theft
criminal antecedents
bail denial

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.64421 of 2025
                    Arising Out of PS. Case No.-15 Year-2025 Thana- GOPALGANJ GRP CASE District-
                                                        Gopalganj
                 ======================================================
                 Sadre Alam @ Md. Sadre Alam S/o Late Abdul Hakim @ Late Mohammad
                 Hakim Miyan R/o - Sain, Ward No. - 5, P.S - Kanti, District- Muzaffarpur,
                 Bihar

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s    :       Mr. Indrajeet Bhushan
                 For the State           :       Mr. Aditya Narayan Singh.1
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE NAWNEET KUMAR
                 PANDEY
                                       ORAL ORDER

3   19-01-2026                      Heard the learned counsel for the petitioner as well as

                   the learned Additional Public Prosecutor for the State.

                                 2. The petitioner is seeking regular bail in connection with

                   Rail P.S. Thawe Case No. 15 of 2025 for the offences punishable

                   under Sections 317(4) and 317(5) of the BNS and Sections 20/22 of

                   the N.D.P.S. Act.

                                 3. As per the prosecution case, on 07.03.2025, police

                   apprehended the petitioner and one co-accused person at Thawe

                   railway station after they attempted to flee. Upon their arrest, officers

                   recovered several mobile phones, stolen personal stuff and 54

                   intoxicated tablets. The apprehended persons including the petitioner

                   confessed to a pattern of drugging travelers’ tea or food to steal their

                   belongings.
             Patna High Court CR. MISC. No.64421 of 2025(3) dt.19-01-2026
                                                          2/2




                                    4. Learned counsel for the petitioner has submitted that

                       that the petitioner is innocent and falsely been implicated in this case.

                       The petitioner has no concern with the alleged recovery. The fact is

                       that on the date of occurrence, the petitioner was returning from

                       Lucknow and was on Thawe railway station for catching a train for

                       Muzaffarpur. The petitioner is in custody since 09.03.2025.

                                    5. Learned APP for the State has opposed the prayer for

                       bail and submitted that the petitioner has five criminal antecedents.

                       32 pieces of intoxicated tablets and some stolen articles have been

                       recovered from possession of the petitioner and allegation against the

                       petitioner is that he along with other, used to make the passengers

                       unconscious by consuming intoxicated tablets and then they used to

                       steal their stuff.

                                    6.      Considering     the    above-mentioned   facts   and

                       circumstances as well as the gravity of the allegation, in my view, the

                       petitioner does not deserve bail. Accordingly, it is rejected.


                                             (Nawneet Kumar Pandey, J)

priyanka/-

U      T

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