Patna High Court

Ranjay Thakur @ Ranjay KumarversusThe State of Bihar

Decided: 12 January 2026
Disposal: BAIL REJECTED
Bench: SATYAVRAT VERMA

Holding

Anticipatory bail was denied as the unrecovered body and uncertain cause of death precluded the grant of relief.

Summary

The petitioner, Dr. Ranjay Thakur, a rural doctor with a clean record, applied for anticipatory bail after being implicated in a case involving the death of a woman, the wife of Naveen Kumar. The prosecution alleged that the petitioner assisted Naveen Kumar and his family in disposing of the dead body, which was later cremated and not recovered, making the cause of death uncertain. The informant claimed the petitioner was aware of the crime and helped conceal evidence by taking the body to his clinic for cremation. The State and the informant opposed the bail, arguing the petitioner’s involvement in the alleged concealment. The Court, after hearing both sides, declined to grant anticipatory bail, noting that the unrecovered body and indeterminate cause of death precluded such relief. Consequently, the petition for anticipatory bail was rejected.

Issues considered

Whether anticipatory bail can be granted when the dead body has not been recovered and the cause of death is not ascertained
Whether the petitioner’s alleged participation in disposing of the body makes him liable to denial of anticipatory bail

Legislation cited

Bihar Narcotic Substances Act, 2023 — s. 238, 3(5), 80(2)
Code of Criminal Procedure, 1973 — s. 438

Subjects

anticipatory bail
Criminal Procedure Code
Section 438
Bihar Narcotic Substances Act
body disposal
murder investigation
grant of bail

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.81378 of 2025
                   Arising Out of PS. Case No.-264 Year-2025 Thana- SHEKHPURA District- Sheikhpura
                 ======================================================
                 Ranjay Thakur @ Ranjay Kumar Son of Baleshwar Thakur Resident of
                 Village- Mandana, P.S.- Hathiyawan, Dist.- Sheikhpura
                                                                              ... ... Petitioner/s
                                                   Versus
                 The State of Bihar
                                                                       ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner      :        Mr. Dinkar Kumar, Advocate
                 For the State           :        Mr. Binod Kumar, APP
                 For the Informant       :        Mr. Mani Bhushan Kumar, Advocate
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
                                       ORAL ORDER

2   12-01-2026                   Heard learned counsel for the petitioner, learned APP

                   for the State as well as learned counsel appearing on behalf of the

                   informant.

                                 2. Petitioner apprehends his arrest in a case registered

                   for the offences punishable under Sections 80(2), 238 and 3(5) of

                   B.N.S., 2023.

                                 3. Learned counsel for the petitioner submits that

                   petitioner is a person with clean antecedent and being a rural

                   doctor came to be implicated in the instant case when he has no

                   concern with the death of the deceased who was wife of Naveen

                   Kumar. It is also submitted that during the course of investigation,

                   it transpired that petitioner helped Naveen Kumar and his family

                   members in disposing of the dead body of the deceased.

                                 4. Learned APP for the State and learned counsel

                   appearing on behalf of the informant vehemently oppose the
               Patna High Court CR. MISC. No.81378 of 2025(2) dt.12-01-2026
                                                           2/2




                         anticipatory bail application.

                                       5. Learned counsel appearing on behalf of the

                         informant submits that petitioner is related to Naveen Kumar and

                         being aware that a crime has been committed and Naveen Kumar

                         and his family members were trying to conceal the evidence, as

                         such, had brought the dead body to the clinic of the petitioner from

                         where petitioner along with others took the dead body for

                         cremation, as would manifest from para-41 of the case diary.

                                       6. After hearing learned counsel for the parties, the

                         Court is not inclined to extend the privilege of anticipatory bail to

                         the petitioner as the dead body was not recovered and the same

                         was cremated, as such, the cause of death could not be ascertained.

                         Accordingly, the prayer for grant of anticipatory bail to the

                         petitioner is hereby rejected in connection with Sheikhpura P.S.

                         Case No.264 of 2025, pending in the court of learned C.J.M.,

                         Sheikhpura/Successor Court.


                                                   (Satyavrat Verma, J)

Sanjay/-

U          T

Continue reading with your account

Checking your session…