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Patna High Court

Satrudhan Kumar @ Shatrughan RamversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

Holding

The court held that bail must be granted as there is no substantive evidence linking the petitioner to the alleged murder.

Summary

The petitioner, Satrudhan Kumar, was arrested in connection with a murder case but his name does not appear in the FIR; it surfaced only during investigation. The prosecution’s case is limited to a single phone call made by the petitioner to the deceased on the day of the incident, with no other evidence linking him to the crime. The petitioner has been in custody since 8 May 2025 and seeks regular bail under Section 103(1) of the BNS. The State opposed bail, but the court noted the lack of material incriminating the petitioner and the length of his pre‑trial detention. Consequently, the court allowed the bail application, ordering release on a bail bond of Rs. 10,000 with two sureties of the same amount.

Issues considered

  • Whether the petitioner is entitled to regular bail under Section 103(1) of the BNS given the absence of incriminating material in the record.

Legislation cited

  • BNS — s. 103(1)

Subjects

  • bail
  • criminal procedure
  • Section 103(1)
  • BNS
  • FIR
  • pre‑trial detention
  • investigation

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.80056 of 2025
                 Arising Out of PS. Case No.-119 Year-2025 Thana- PAKRIDAYAL District- East Champaran
                 ======================================================
                 Satrudhan Kumar @ Shatrughan Ram Son of Ram Dev Ram @ Ramdeo Ram
                 Resident of village - Pakaridayal, P.S.- Pakaridayal, District - East
                 Champaran.

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Sunil Kumar No.Iii, Advocate
                 For the Opposite Party/s :       Mr. Anil Prasad Singh, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                       ORAL ORDER

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

                   A.P.P. for the State .

                                  2. Petitioner seeks regular bail            for the offences

                   punishable under Sections 103 (1) of BNS.

                                3 . As per prosecution story, informant received

                   information that that some unknown miscreants had committed

                   the murder of her daughter and had thrown her body in a nearby

                   maize field.

                                4. Learned counsel for the petitioner submits that

                   petitioner is not named in the F.I.R.. The name of the petitioner

                   transpired during course of investigation . As per paragraph 20

                   of the case diary , it appears that this petitioner was in touch

                   with the deceased through mobile and on the alleged date of
            Patna High Court CR. MISC. No.80056 of 2025(3) dt.04-02-2026
                                                        2/2




                      incident regular call was made by this petitioner on the mobile

                      of deceased. Save and except, there is no other material on the

                      record to show the complicity of this petitioner in the aforesaid

                      occurrence . Petitioner is in custody since 08.05.2025 .

                                   5 . Learned A.P.P. for the State opposes the bail

                      application of the petitioner.

                                    6. Considering the aforesaid facts and circumstances

                      of the case and period of custody , the bail application is

                      allowed. Let the above named petitioner be released on bail on

                      furnishing bail-bond of Rs. 10,000/- (ten thousand) with two

                      sureties of the like amount each to the satisfaction of the learned

                      ADJ 2nd East Champaran Motihari                      in connection with

                      Pakaridayal P.S. Case No. 119 of 2025 .



                                            (Prabhat Kumar Singh, J)
Koushik/-

U      T


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