Patna High Court

Kanchan RishiversusThe State of Bihar

Decided: 28 January 2026
Disposal: BAIL REJECTED
Bench: PRABHAT KUMAR SINGH

Holding

The court held that, considering the seriousness of the allegations and the petitioner’s prior criminal record, anticipatory bail could not be granted.

Summary

The petitioner, Kanchan Rishi, sought anticipatory bail after his name surfaced in a raid that recovered stolen vehicles from a godown, based on a co-accused's confessional statement. The case involved alleged offences punishable under Sections 317(4), 317(5) and 111(1) of the Bihar Narcotic Substances Act, 2023. The petitioner has six prior criminal cases, some of a similar nature. The primary issue was whether anticipatory bail could be granted in view of the seriousness of the charges and the petitioner’s criminal antecedent. The court examined the statutory provisions and the relevance of the petitioner’s past record. Concluding that the nature of the accusation and the petitioner’s antecedents warranted denial of bail, the court rejected the anticipatory bail application. The petition was therefore dismissed.

Issues considered

Whether anticipatory bail can be granted to a person facing charges under Sections 317(4), 317(5) and 111(1) of the B.N.S., 2023 given his criminal antecedent.

Legislation cited

B.N.S., 2023 — s. 111(1), 317(4), 317(5)

Subjects

anticipatory bail
criminal antecedent
Section 317
Section 111
Bihar Narcotic Substances Act
high court

Judgment

                         IN THE HIGH COURT OF JUDICATURE AT PATNA
                                 CRIMINAL MISCELLANEOUS No.82488 of 2025
                       Arising Out of PS. Case No.-328 Year-2025 Thana- PURNEA SADAR District- Purnia
                    ======================================================
                    Kanchan Rishi S/o Pakuri Rishi @ Pappu Rishi Resident of - Gulabhagh, P.S
                    - Sadar (T.O.P Gulabbagh), District - Purnea
                                                                              ... ... Petitioner/s
                                                        Versus
                    The State of Bihar
                                                                       ... ... Opposite Party/s
                    ======================================================
                    Appearance :
                    For the Petitioner/s     :       Mr.Bidhu Ranjan
                    For the Opposite Party/s :       Mr.Jitendra Kumar Singh
                    ======================================================
                    CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                          ORAL ORDER

3      28-01-2026                    Heard learned counsel for the petitioner and State.

                                   2. The petitioner apprehends his arrest in a case,

                      registered for offence punishable under Sections 317(4), 317(5),

                      111(1) of the B.N.S., 2023.

                                   3. A raid was conducted and stolen vehicles were

                      recovered from the godown of Ajit Chaudhary. During

                      investigation, name of the petitioner surfaced on the basis of

                      confessional statement of co-accused Md. Azizul Haque.

                      Petitioner has got six criminal antecedent, out of which, some

                      are of similar nature.

                                   4. Considering the nature of accusation and criminal

                      antecedent,       the prayer for anticipatory bail of petitioner is

                      rejected.


                                             (Prabhat Kumar Singh, J)
anay

U        T

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