Patna High Court
Satyendra SahversusThe State of Bihar
- Decided
- Disposal
- BAIL REJECTED
- Bench
- R P MISHRA
Holding
The bail petition is dismissed; the petitioner is not entitled to bail at this stage.
Summary
The petitioner, Satyendra Sah, was arrested and has been in judicial custody since 21 July 2024 for offences under Sections 137(2), 140(3), 96, 3(5), 103(1) and 238 of the Bharatiya Nyaya Sanhita, 2023. He applied for bail, but an earlier order on 17 January 2025 rejected regular bail due to the gravity of the accusations. A subsequent report indicated that the trial was at the stage of examining prosecution witnesses and was likely to conclude within six months. The petitioner argued that he was being detained without justification, while the State opposed bail. The Court found no fresh ground to revisit the bail issue, noted the advanced stage of trial, and therefore rejected the bail petition, directing the lower court to expedite the trial within five months and allowing the petitioner to renew the bail application if the trial is not concluded within that period.
Issues considered
- Whether bail should be granted to the petitioner at an advanced stage of trial for serious offences under the Bharatiya Nyaya Sanhita, 2023.
Legislation cited
- Bharatiya Nyaya Sanhita, 2023 — s. 103(1), 137(2), 140(3), 238, 3(5), 96
Subjects
- bail
- criminal procedure
- Bharatiya Nyaya Sanhita
- trial stage
- judicial custody
- serious offences
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.74779 of 2025
Arising Out of PS. Case No.-60 Year-2024 Thana- PURNAHYA District- Sheohar
======================================================
Satyendra Sah S/O Harichandra Sah @ Harishchandra Sah R/O Village-
Parsauni Gop, Sonaul Sultan, P.S- Purnahiya, Distt.- Sheohar.
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr. Deepak Kumar, Advocate
For the Opposite Party/s : Mr. Ram Priya Sharan Singh, APP
======================================================
CORAM: HONOURABLE MR. JUSTICE RUDRA PRAKASH
MISHRA
ORAL ORDER
3 09-01-2026 Heard learned counsel for the petitioner and learned
APP for the State.
2. The petitioner seeks bail in connection with Sessions
Tr. No. 14 of 2025 arising out of Purnahiya P.S. Case No. 60 of
2024 instituted for the offences under Sections 137(2), 140(3),
96, 3(5) of the Bharatiya Nyaya Sanhita, 2023 and later on
Section 103(1), 238 of Bharatiya Nyaya Sanhita, 2023.
3. Earlier vide order dated 17.01.2025 passed in Cr.
Misc. No. 81521 of 2024 regular bail of the petitioner was
rejected by this Court considering the nature of accusation and
gravity of offence.
4. In compliance of the order dated 31.10.2025 a report
dated 04.11.2025 with regard to the present stage of trial has
Patna High Court CR. MISC. No.74779 of 2025(3) dt.09-01-2026
2/2
been received. From perusal of the aforesaid report, it appears
that the case is fixed for examination of prosecution witnesses.
It is further reported that trial is likely to be concluded within
six months.
5. Learned counsel for the petitioner submits that the
petitioner is languishing in judicial custody since 21.07.2024
without any rhymes or reason.
6. Learned APP for the State opposes the prayer for
grant of bail.
7. There is no fresh ground to consider the bail petition
of the petitioner. From the aforesaid report, it appears that the
trial is going on and is at an advance stage.
8. In view of the above, the prayer for bail of the
petitioner is again rejected with a direction to the court below to
expedite the trial and conclude the same expeditiously
preferably within a period of five months from today. If the trial
is not concluded within the period of five months, as stated
above, the petitioner will be at liberty to renew his prayer before
the court below.
(Rudra Prakash Mishra, J)
Alok Verma/-
U T
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