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Patna High Court

Ranjan Bhuiyan @ Mukhiya Bhuiyan @ Muchiya Bhuiyan @ Ranjan KumarversusThe State of Bihar

Decided
Disposal
DISMISSED

Holding

Bail was denied as the petitioner’s confession and the nature of the offences did not warrant release.

Summary

The petitioner, Ranjan Bhuiyan, applied for bail in a criminal case (PS Case No. 21 of 2025) for offences under Sections 103(1) and 3(5) of the Bharatiya Nyaya Sanhita. The prosecution alleged that the petitioner, acting as a driver, called the deceased and the next day the dead body was discovered. The petitioner made a self‑incriminating statement confessing guilt. He has been in custody since 5 May 2025. The High Court, after hearing counsel, found the confession and the seriousness of the charges sufficient to deny bail, dismissing the application while noting that the order is limited to the bail application and does not prejudice the trial.

Issues considered

  • Whether bail should be granted to an accused who has confessed to the offence and is charged under Sections 103(1) and 3(5) of the Bharatiya Nyaya Sanhita.

Legislation cited

Subjects

  • bail
  • confession
  • criminal procedure
  • Bharatiya Nyaya Sanhita
  • Section 103
  • Section 3
  • high court
  • denial of bail

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.77698 of 2025
                        Arising Out of PS. Case No.-21 Year-2025 Thana- Bodhibigaha District- Gaya
                 ======================================================
                 Ranjan Bhuiyan @ Mukhiya Bhuiyan @ Muchiya Bhuiyan @ Ranjan Kumar
                 S/O Rajeshwar Bhuiyan R/O Village- Khadagpur, P.S- Hariharganj, Dist.-
                 Palamu (Jharkhand).

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :        Mr.Aman Vishal, Advocate
                 For the State            :        Mr.Syed Ehteshamuddin, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
                                       ORAL ORDER

5   30-03-2026                   Heard learned counsel for the petitioner and learned

                   APP for the State.

                                 2. The petitioner seeks bail in connection with Bodhi

                   Bigha P.S. Case No. 21 of 2025 registered for the offence

                   punishable under Sections 103(1) and 3(5) of the Bharatiya

                   Nyaya Sanhita.

                                 3. As per the prosecution case, the deceased was

                   called by the petitioner, who was the driver and subsequently, on

                   the next day, the dead body of the deceased was found.

                                 4. In his self inculpatory statement, the petitioner has

                   confessed his guilt.

                                 5. The petitioner is in custody since 05.05.2025.

                                 6. Considering the aforesaid, I am not inclined to
           Patna High Court CR. MISC. No.77698 of 2025(5) dt.30-03-2026
                                                       2/2




                     grant bail to the petitioner.

                                  7. Accordingly, the application stands dismissed.

                                  8. It is, however, clarified that the observations made

                     herein are limited to the adjudication of the present bail

                     application and shall not prejudice the case of the petitioner at

                     any subsequent stage of the trial and this Court has not express

                     any opinion on the merits of the case.


                                                                          (Sandeep Kumar, J)

P. Kumar

U     T


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