Patna High Court

Dinesh SinghversusThe State of Bihar

Decided: 4 February 2026
Disposal: BAIL REJECTED
Bench: R P MISHRA

Holding

Bail was denied as the trial was at an advanced stage and no fresh ground was shown.

Summary

The petitioner, Dinesh Singh, was charged under Sections 395 and 412 of the Indian Penal Code for dacoity and robbery. He applied for bail after being in judicial custody since 12 January 2025. The High Court had earlier rejected regular bail, citing the gravity of the offences. The State opposed bail, relying on a 2024 Supreme Court decision that bail is ordinarily denied once trial proceeds in serious offences. The Court noted that the trial was at an advanced stage with several charge‑sheeted witnesses examined and found no fresh ground to grant bail. Consequently, the bail petition was dismissed and the trial was directed to be completed within three months, with a provision to renew the bail application if the deadline is missed.

Issues considered

Whether bail can be granted to an accused of dacoity and robbery at an advanced stage of trial
Whether the Supreme Court precedent in X vs. State of Rajasthan applies to deny bail in this case

Legislation cited

Indian Penal Code — s. 395, 412

Subjects

bail
serious offences
dacoity
robbery
trial stage
high court
judicial custody
Supreme Court precedent

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.75316 of 2025
                   Arising Out of PS. Case No.-526 Year-2023 Thana- UDWANTNAGAR District- Bhojpur
                 ======================================================
                 Dinesh Singh S/O Bindesh Singh @ Vijesh Singh R/O Village- Manaini, P.S.-
                 Charpokhari, Distt.- Bhojpur

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr. Ashok Singh, Advocate
                 For the Opposite Party/s :      Mr. Manoj Kumar, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE RUDRA PRAKASH
                 MISHRA
                                       ORAL ORDER

3   04-02-2026               Heard learned counsel for the petitioner and learned APP

                   for the State.

                             2. The petitioner seeks bail in connection with

                   Udwantnagar (Gajrajganj) P.S. Case No. 526 of 2023, Sessions

                   Trial No. 263 of 2025 instituted for the offences under Sections

                   395 and 412 of the Indian Penal Code.

                             3. Earlier vide order dated 28.03.2025 passed in Cr.

                   Misc. No. 17502 of 2025, regular bail of the petitioner was

                   rejected by this Court considering the nature and gravity of

                   offence.

                             4. A report dated 19.11.2025 with regard to the present

                   stage of trial has been received. From perusal of the aforesaid

                   report, it appears that there are seven charge-sheeted witnesses
Patna High Court CR. MISC. No.75316 of 2025(3) dt.04-02-2026
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          and two have already been examined.

                   5. Learned counsel for the petitioner submits that the

          petitioner is languishing in judicial custody since 12.01.2025

          without any rhymes or reason.

                   6. Learned APP for the State opposes the prayer for

          grant of bail. Learned APP for the State relied upon a decision

          of the Hon’ble Apex Court reported in 2024 SCC OnLine SC

          3539 (X. vs. State of Rajasthan & Anr.), wherein in paragraph

          no. 14, the Hon’ble Apex Court has held has under:

                          “14. Ordinarily in serious offences like rape,

                          murder, dacoity, etc., once the trial commences and

                          the prosecution starts examining its witnesses, the

                          Court, be it the Trial Court or the High Court

                          should be loath in entertaining the bail application

                          of the accused.”

                   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 three months from today. If the
           Patna High Court CR. MISC. No.75316 of 2025(3) dt.04-02-2026
                                                       3/3




                     trial is not concluded within the period of three 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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