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Patna High Court

Sanjeev Kumar @ Sanjeev Mukhiya @ Lutan MukhiyaversusThe State of Bihar

Decided
Disposal
DISMISSED

Holding

The court denied bail to the petitioner, dismissing the bail application.

Summary

The petitioner, Sanjeev Kumar, was arrested in connection with a large-scale leak of question papers for the Teachers Recruitment Examination-3 and charged under multiple provisions of the IPC, the Bihar Conduct Examination Act and the IT Act. The prosecution alleged that he was the king‑pin of the gang, that he was an absconder with a Rs 3 lakh reward on his head, and that several other accused had named him in their statements. The petitioner applied for bail, claiming custody since 25‑04‑2025, but the court noted the seriousness of the offences, his alleged leadership role, and the pending trials in related cases. Consequently, the court was not inclined to grant bail and dismissed the application. The order also directed the Economic Offences Unit and the Special Judge to expedite the trials in two earlier related cases.

Issues considered

  • Whether bail should be granted to the petitioner despite the serious charges of cheating, forgery, conspiracy and involvement in a question‑paper leak.
  • Whether the petitioner’s alleged status as king‑pin, absconder and the reward declared against him preclude the grant of bail.

Legislation cited

Subjects

  • bail
  • economic offences
  • question paper leak
  • IPC
  • IT Act
  • Bihar Conduct Examination Act
  • absconder
  • reward
  • trial expedite

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.78873 of 2025
                     Arising Out of PS. Case No.-6 Year-2024 Thana- ECONOMIC OFFENCES, BIHAR
                                                       District- Patna
                 ======================================================
                 Sanjeev Kumar @ Sanjeev Mukhiya @ Lutan Mukhiya Son of Janak Kishor
                 Prasad R/o Village - Balwa(Shahpur), P.S. - Nagarnausa, Dist. -
                 Nalanda(Bihar).

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :    Mr.Arun Kumar
                 For the Opposite Party/s :    Mr.Vishwanath Pd. Sinha, Sr. Adv.
                                               Mr. Vijay Anand
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
                                       ORAL ORDER

8   07-04-2026                  Heard the parties

                                2. The petitioner seeks bail in connection with

                   Economic Offence P.S. Case No. 6 of 2024 for the offences

                   punishable under Sections 420, 467, 468, 471 and 120(B)/34 of

                   the Indian Penal Code and section 3 & 10 of the Bihar Conduct

                   Examination Act, 1981 as also section 66 of the Information

                   Technology Act, 2000.

                                3. As per the prosecution story, the allegation is that

                   the Economic Offence Unit upon information that the accused

                   are involved in the leakage of the examination papers relating to

                   Teachers Recruitment Examination-3 which was to take place

                   on 15.03.2024 by the Bihar Public Service Commission reached
Patna High Court CR. MISC. No.78873 of 2025(8) dt.07-04-2026
                                            2/3




          Rajauli, Nawada (Bihar). As number of Buses/Scorpios with

          Bihar registration were found near Toll Plaza, within the

          jurisdiction of Kora Police Station. EOU’ further got

          information that some of the accused are present in Karbigahiya

          station parking area with several set of question papers. It

          accordingly, raided the place and several bags kept in number of

          vehicles were recovered/seized. 258 persons were arrested from

          Kohinoor Banquet Hall, most of them were candidates.

                       4. The petitioner is in custody since 25.04.2025.

                       5. During investigation, one Sumit and others have

          been arrested and he has named one Dr. Shiv Kumar Mukhiya in

          his self-inculpatory statement. Thereafter, Dr. Shiv Kumar

          Mukhiya has named the petitioner in his self-inculpatory

          statement. One Prem Sagar has also named the petitioner as

          king-pin of the question paper leak gang and similar is the

          statement of one Rakesh Ranjan.

                       6. The petitioner is accused in six more cases and all

          of them are related to question paper leak. The petitioner has

          been using mobile which is in the name of Ayushi Kumari. The

          petitioner is an absconder also and an award of Rs. 3 lakhs was

          declared for his arrest.

                       7. Considering the fact that the petitioner is the king
          Patna High Court CR. MISC. No.78873 of 2025(8) dt.07-04-2026
                                                      3/3




                    pin of a gang which is involved in question paper leak, this

                    Court is not inclined to grant bail to the petitioner.

                                 8. Accordingly, this application is dismissed.

                                 9. From the petition, it appears that Economic

                    Offences Unit has charge-sheeted the petitioner in a number of

                    cases including the EOU P.S. Case No. 12 of 2012 and EOU

                    P.S. Case No. 30 of 2013 which appears to be for question paper

                    leak but in these cases, the trial has not been concluded yet.

                                 10. In these circumstances, the ADG, Economic

                    Offences Unit, Bihar, Patna is directed to ensure that the trial of

                    the accused persons in EOU P.S. Case No. 12 of 2012 and EOU

                    P.S. Case No. 30 of 2013 is concluded at the earliest.

                                 11. The Special Judge, Patna, in whose court, the

                    trials of EOU P.S. Case No. 12 of 2012 and EOU P.S. Case No.

                    30 of 2013 are pending, is also directed to expedite the trial.

                                 12. Let a copy of this order be communicated to the

                    Director General of Police, Bihar and Principal District and

                    Sessions Judge, Patna through FAX for its compliance.


                                                              (Sandeep Kumar, J)
Vikas/-
U


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