Patna High Court
Manu Rai @ Manu Kumar Rai @ Monu RaiversusThe State of Bihar
- Decided
- Disposal
- DISMISSED
- Bench
- SANDEEP KUMAR
Holding
The court upheld the earlier decision and denied bail to the petitioner.
Summary
Manu Rai applied for regular bail for offences under Sections 319(2), 313(4), 303(2), 336(3) and 340(2) of the Bharatiya Nyaya Sanhita, 2023, relating to an alleged ATM fraud. This was his second bail application after a prior denial on 24‑09‑2025. The prosecution highlighted the seriousness of the fraud and the petitioner’s eight prior criminal antecedents. The petitioner’s counsel argued innocence and reliance on a co‑accused’s confessional statement, but the court found no merit to overturn the earlier order. Consequently, the court dismissed the bail application and directed the lower court to frame charges promptly.
Issues considered
- Whether the petitioner is entitled to regular bail despite the nature of the alleged ATM fraud and his criminal antecedents
- Whether the earlier bail denial can be reviewed in the second application
Legislation cited
- Bharatiya Nyaya Sanhita, 2023 — s. 303(2), 313(4), 319(2), 336(3), 340(2)
Subjects
- bail
- ATM fraud
- criminal antecedents
- Bharatiya Nyaya Sanhita
- high court
- regular bail
- review of order
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.84954 of 2025
Arising Out of PS. Case No.-201 Year-2024 Thana- KHAIRA District- Saran
======================================================
Manu Rai @ Manu Kumar Rai @ Monu Rai Son of Raju Rai @ Raju Kumar
R/o Village - Chhota Telpa, Goria Toli, P.S. - Chapra Town, Dist. - Saran at
Chapra.
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr. Maheshwar Prasad
For the Opposite Party/s : Ms. Madhuri Lata
======================================================
CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
ORAL ORDER
2 31-01-2026 Heard the learned counsel for the petitioner and the
learned APP for the State.
2. This is the 2nd attempt of the petitioner. The
petitioner seeks bail in connection with Khaira P.S. Case No.
201 of 2024 registered for the offence under Sections 319(2),
313(4), 303(2), 336(3), 340(2) of the Bharatiya Nyaya Sanhita,
2023.
3. Earlier the bail application of the petitioner was
rejected on 24.09.2025 in Cr. Misc. No. 66197 of 2025 which
reads as follows:-
Heard learned counsel for the petitioner
and learned Additional Public
Prosecutor for the State.
2. The petitioner seeks bail in connection
with Khaira P.S. Case No. 201/2024
registered for the offences punishable
Patna High Court CR. MISC. No.84954 of 2025(2) dt.31-01-2026
2/3
under Sections 319(2), 318(4), 303(2),
336(3), 340(2) of B.N.S.
3. As per the prosecution case, the
petitioner is accused of committing
A.T.M. fraud.
4. Learned counsel for the petitioner
submits that petitioner is innocent and
has falsely been implicated in the case.
Learned counsel further submits that
the name of the petitioner has come in
the confessional statement of co-
accused Rakesh Kumar Yadav who was
apprehended on the place of incident.
Learned counsel further submits that
the petitioner is incustody since
02.06.2025 and he has got eight
criminal antecedents in which he is on
bail.
5. Learned APP for the State has opposed
the prayer for regular bail of the
petitioner.
6. Considering the fact that the petitioner
was involved in ATM fraud and has got
eight criminal antecedents, this Court
is not inclined to grant bail to the
petitioner.
7. Accordingly, this application stands
dismissed.
4. This Court finds no ground to review its earlier
order. Accordingly, this application for regular bail stands
Patna High Court CR. MISC. No.84954 of 2025(2) dt.31-01-2026
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rejected.
5. The Court below is directed to frame the charges at
the earliest as it has been submitted by the learned counsel for
the petitioner that only cognizance has been taken so far.
(Sandeep Kumar, J)
Shishir/-
U T
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