Patna High Court

Dharmendra Kumar PandeyversusThe State of Bihar

Decided: 22 April 2026
Disposal: BAIL REJECTED
Bench: PURNENDU SINGH

Holding

The court held that pre‑arrest bail could not be granted in view of the nature of the allegations.

Summary

The petitioner, Dharmendra Kumar Pandey, was implicated in a FIR (Kurtha P.S. Case No. 174 of 2025) for offences under Section 103 of the BNS and Section 27 of the Arms Act. He applied for pre‑arrest bail before the Patna High Court. The learned counsel for the petitioner argued for the grant of bail, while the State opposed the same. Justice Purnendu Singh observed that, given the seriousness of the allegations recorded in the FIR, the court could not enlarge the petitioner on pre‑arrest bail. Consequently, the bail application was dismissed, with the court directing the petitioner to seek appropriate remedy under law. The order was pronounced on 22‑04‑2026.

Issues considered

Whether the petitioner is entitled to pre‑arrest bail in a case involving offences under Section 103 of the BNS and Section 27 of the Arms Act

Legislation cited

Arms Act — s. 27
BNS — s. 103

Subjects

pre‑arrest bail
criminal procedure
Arms Act
BNS
Section 103
bail denial

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                               CRIMINAL MISCELLANEOUS No.7261 of 2026

                          Arising Out of PS. Case No.-174 Year-2025 Thana- Kurth District- Arwal
                 ======================================================
                 Dharmendra Kumar Pandey S/O Krishna Pandey Resident Of Village -
                 Pandey Bigha, P.O- Baghoe, P.S- Haspura, Dist.- Aurangabad

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s      :       Mr. Uday Prasad Singh, Advocate
                 For the Opposite Party/s :        Mr. Sanjay Kumar Singh, A.P.P.
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PURNENDU SINGH
                                       ORAL ORDER

3   22-04-2026                          Heard Mr. Uday Prasad Singh, learned counsel

                   appearing on behalf of the petitioner and Mr. Sanjay Kumar

                   Singh, learned APP for the State.

                                 2. The petitioner seeks pre-arrest bail in connection

                   with Kurtha P.S. Case No. 174 of 2025 registered for the offence

                   punishable under Sections 103 of the BNS and Section 27 of the

                   Arms Act.

                                 3. Considering the nature of allegation made against

                   the petitioner in the FIR, I am not inclined to enlarge the

                   petitioner on pre-arrest bail.

                                 4. However, the petitioner may avail appropriate

                   remedy in accordance with law.
              Patna High Court CR. MISC. No.7261 of 2026(3) dt.22-04-2026
                                                          2/2




                                     5. Accordingly, the present bail application stands

                        disposed of.



                                                  (Purnendu Singh, J)
Niraj/-

U         T

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