Patna High Court

RANJAY SAHANI @ RANJAY KUMAR SAHANIversusThe State of Bihar

Decided: 20 February 2026
Disposal: BAIL GRANTED
Bench: SONI SHRIVASTAVA

Holding

Bail was granted to the petitioner on the condition of a Rs.10,000 bond and two sureties.

Summary

The petitioner, Ranjay Sahani, was arrested in a case involving offences under Sections 341, 342, 324, 307 and 34 of the Indian Penal Code, stemming from an FIR that named three unknown assailants who fired at a shop owner’s brother. The petitioner’s name appeared only in a co‑accused’s confessional statement and not in the FIR itself. He has been in custody since 1 March 2025 with no investigation progress or charge‑sheet filed. The State opposed bail, citing the petitioner’s alleged criminal antecedents, while the petitioner’s counsel highlighted the lack of direct allegation and the fact that a similarly situated co‑accused, Shivam Sahani, had already been granted bail by a coordinate bench. Considering the absence of substantive evidence against the petitioner and the precedent of bail to the co‑accused, the court ordered bail on a bond of Rs.10,000 with two sureties, subject to conditions of appearance.

Issues considered

Whether the petitioner, whose name is not in the FIR but appears in a co‑accused’s confession, is entitled to bail.
Whether the petitioner’s alleged criminal antecedents justify denial of bail.

Legislation cited

Indian Penal Code — s. 307, 324, 34, 341, 342

Subjects

bail
Indian Penal Code
criminal procedure
confessional statement
pre‑trial detention

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.80260 of 2025
                   Arising Out of PS. Case No.-271 Year-2021 Thana- MOTIHARI MUFASIL District- East
                                                        Champaran
                 ======================================================
                 Ranjay Sahani @ Ranjay Kumar Sahani S/O- Vinod Sahani R/V- Murarpur
                 Baluaa Tola Ps- Harsidhi Dist- East Champaran
                                                                        ... ... Petitioner/s
                                                     Versus
                 The State of Bihar                            ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Shamir Mehra
                                                  Mr. Rajeev Ranjan Ray
                 For the Opposite Party/s :       Mr. Sharda Kumari
                 ======================================================
                 CORAM: HONOURABLE JUSTICE SMT. SONI SHRIVASTAVA
                                       ORAL ORDER
4   20-02-2026                   Heard learned counsel for the petitioner and learned

                   Additional Public Prosecutor for the State.

                                 2. The petitioner seeks bail in a case registered for the

                   offence punishable under Sections 341, 342, 324, 307, 34 of the

                   Indian Penal Code.

                                 3. As per FIR, three unknown miscreants came at the

                   shop of the brother of the informant on a motorcycle and fired at

                   him in which he sustained injury.

                                 4. Learned counsel for the petitioner submits that the

                   First Information Report was lodged against three unknown

                   miscreants who had resorted to firing resulting in injuries to the

                   brother of the informant. The petitioner was not named in the

                   FIR rather his name transpired in the confessional statement of

                   co-accused with no specific allegation. Further, similarly

                   situated co-accused Shivam Sahani has already been granted

                   bail by a coordinate Bench of this Court vide order dated
             Patna High Court CR. MISC. No.80260 of 2025(4) dt.20-02-2026
                                                         2/2




                       22.09.2022 passed in Cr. Misc. No. 37379 of 2022. The

                       petitioner is in custody since 01.03.2025 and neither any TIP

                       was held nor there has been substantial progress in the case.

                                    5. Learned APP for the State has opposed the

                       application for bail on the ground that the petitioner has criminal

                       antecedent. In response, it has been submitted that the petitioner

                       is on bail in all the cases.

                                        6. Taking into consideration the facts and

                       circumstances and also considering the fact that similarly

                       situated co-accused has already been granted bail, let the above

                       named petitioner, be enlarged on bail on furnishing bail bond of

                       Rs.10,000/- (Rupees Ten Thousand) with two sureties of the like

                       amount each to the satisfaction of the learned court below where

                       the case is pending/successor court in connection with Muffasil

                       P.S. Case No. 271 of 2021, subject to the conditions that the

                       petitioner shall appear on each and every date till conclusion of

                       trial and if the petitioner does not appear on two consecutive

                       dates without any substantial and satisfactory reason, the

                       learned court below would be at liberty to cancel his bail bonds.



devendra/-                                       (Soni Shrivastava, J)
U      T

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