Patna High Court

Suman Singh @ Suman Kr. SinghversusThe State of Bihar

Decided: 20 February 2026
Disposal: BAIL REJECTED
Bench: PRABHAT KUMAR SINGH

Holding

Anticipatory bail was denied because the alleged assault resulted in a grievous injury, justifying refusal of relief.

Summary

The petitioner, Suman Singh, filed an anticipatory bail application fearing arrest in connection with FIR No. 378/2025 alleging assault on an informant with an iron rod, resulting in grievous injury as certified by a doctor. The FIR charges him under Sections 126(2), 115(2), 117(2), 109(1), 352, 351(2), 74 and 3(5) of the Bhartiya Nyaya Sanhita, 2023. The petitioner sought bail on the ground of apprehended arrest, while the State opposed the relief. The Court examined the seriousness of the alleged assault and the grievous nature of the injury. Considering the severity of the offence and the injury, the Court held that anticipatory bail could not be granted. Consequently, the petition for anticipatory bail was dismissed.

Issues considered

Whether anticipatory bail can be granted to the petitioner under the Bhartiya Nyaya Sanhita given the nature of the alleged assault and the grievous injury caused

Legislation cited

Bhartiya Nyaya Sanhita, 2023 — s. 109(1), 115(2), 117(2), 126(2), 3(5), 351(2), 352, 74

Subjects

anticipatory bail
assault
grievous injury
criminal procedure
Bhartiya Nyaya Sanhita

Judgment

                         IN THE HIGH COURT OF JUDICATURE AT PATNA
                                 CRIMINAL MISCELLANEOUS No.7986 of 2026
                          Arising Out of PS. Case No.-378 Year-2025 Thana- OBRA District- Aurangabad
                    ======================================================
                    Suman Singh @ Suman Kr. Singh Son of Sachidanand Singh Resident of
                    Village- Bel, P.S.- Obra, District- Aurangabad
                                                                          ... ... Petitioner/s
                                                         Versus
                    The State of Bihar
                                                                   ... ... Opposite Party/s
                    ======================================================
                    Appearance :
                    For the Petitioner/s     :        Mr.Manoj Kumar
                    For the Opposite Party/s :        Mr.Jai Narain Thakur
                    ======================================================
                    CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                          ORAL ORDER

2      20-02-2026                    Heard learned counsel for the petitioner and learned

                      A.P.P. for the State.

                                   2. The petitioner apprehends his arrest in Obra P.S.

                      Case No. 378/2025, registered for offence under Sections

                      126(2), 115(2), 117(2), 109(1), 352, 351(2), 74 & 3(5) of

                      Bhartiya Nyaya Sanhita, 2023.

                                   3. As per F.I.R., this petitioner assaulted informant by

                      means of iron rod. Doctor has found the injury grievous in

                      nature.

                                   4. Considering the nature of injury, the prayer for

                      anticipatory bail of petitioner is rejected.



                                             (Prabhat Kumar Singh, J)
anay

U        T

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