Created by Fuzzy Cloud

Patna High Court

Satyanarayan DasversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

Holding

The Court held that the lack of substantive evidence and the remoteness of the allegations warranted the grant of bail to the petitioners.

Summary

The Patna High Court heard two bail petitions arising from PS Murliganj Case No.333/2025, in which the petitioners, Indal Kumar and Satyanarayan Das, were accused of murdering the parents of an informant under Sections 103(1) and 3(5) of the Bihar Negotiable Securities Act, 2023. The prosecution alleged that the informant named the petitioners as co‑accused, but the defence argued that there was no eyewitness or circumstantial evidence linking them to the crime and that the allegation was motivated by a land dispute. The informant’s counsel maintained that the petitioners were instrumental in the murders, while the State opposed bail. The Court noted the remoteness and vagueness of the allegations, the lack of substantive material, and the fact that a charge sheet had already been filed, and considered the length of custody. Consequently, the Court ordered the release of both petitioners on bail with a bond of Rs 10,000 and specific conditions under Section 480(3) of the BNSS. The bail order was subject to compliance with the stipulated conditions and the satisfaction of the Chief Judicial Magistrate, Madhepura.

Issues considered

  • Whether the evidence on record is sufficient to justify continued detention of the petitioners.
  • Whether the petitioners are entitled to bail under Section 480(3) of the Bihar Negotiable Securities Act, 2023 despite the seriousness of the alleged offence.

Subjects

  • bail
  • insufficient evidence
  • land dispute
  • murder
  • Section 480(3)
  • Bihar Negotiable Securities Act
  • criminal procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.82633 of 2025
                    Arising Out of PS. Case No.-333 Year-2025 Thana- MURLIGANJ District- Madhepura
                 ======================================================
                 Indal Kumar @ Indra Kishore Kumar, Son of Satyanarayan Das, Resident of
                 Ward No. 15, Prasadi Chouk, Post- Rajni, P.S.- Murliganj, District-
                 Madhepura

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

                                                        ... ... Opposite Party/s
                 ======================================================
                                                         with
                              CRIMINAL MISCELLANEOUS No. 85302 of 2025
                    Arising Out of PS. Case No.-333 Year-2025 Thana- MURLIGANJ District- Madhepura
                 ======================================================
                 Satyanarayan Das, S/O Late Jageshwar Das @ Jagarnath Das, Resident Of
                 Ward No.-15, Prasadi Chouk, Post Rajni, P.S - Murliganj, District -
                 Madhepura

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 (In both the cases)
                 For the Petitioner/s    :       Mr. Pramod Kumar Singh, Advocate
                                                 Mr.Rahul Kumar Singh, Advocate
                 For the State           :       Mr.Jai Narain Thakur, APP
                 For the Informant       :       Mr. Barun Kumar Singh, Advocate
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ARUN KUMAR JHA
                                       ORAL ORDER

3   11-02-2026                     Since both the bail petitions arise out of Murliganj

                   P.S. Case No. 333/2025, as such, they have been taken up

                   together and are being disposed of by this common order.

                                 2. Heard learned counsel for the petitioners, learned

                   A.P.P. for the State and learned counsel for the informant.

                                 3. In the present case, the petitioners seek bail in
Patna High Court CR. MISC. No.82633 of 2025(3) dt.11-02-2026
                                            2/4




          connection with Murliganj P.S. Case No. 333/2025, registered

          for the offence under Sections 103(1), 3(5) of the BNS, 2023.

                       4. As per prosecution case, parents of the informant

          were murdered and the name of the petitioners and other co-

          accused persons has been given in the FIR by the informant who

          might be involved in the murder of her parents.

                       5. The learned counsel for the petitioners submits that

          petitioners are innocent and have been falsely implicated in this

          case. There is no eye witness to the alleged occurrence and even

          there is no circumstantial evidence to show the complicity of the

          petitioners. No specific overt act has been attributed to the

          petitioners towards committing the murder of the parents of the

          informant. There is admitted land dispute between the parties

          and Title Suit No.14 of 2019 has been pending in this

          connection. The motive given by the informant is to grab the

          land of deceased as the deceased had no son. The learned

          counsel further submits that the allegation on this account is not

          believable and there is no evidence to connect the petitioners

          with the alleged crime. Nothing incriminating has been

          recovered from the person/possession of the petitioners. The

          petitioner Indal Kumar is having antecedent of three cases and

          he is on bail in those cases. The petitioner Satyanarayan Das is
Patna High Court CR. MISC. No.82633 of 2025(3) dt.11-02-2026
                                            3/4




          having antecedent of five cases and he is on bail in one such

          cases and in four cases, final form has been submitted against

          him. The petitioners are in custody since 06.07.2025 and charge

          sheet has been submitted.

                       6. Learned A.P.P. vehemently opposes the submission

          made on behalf of the petitioners.

                       7. The learned counsel for the informant submits that

          the petitioners were instrumental in causing the death of parents

          of the informant.

                       8. Having regard to the fact and circumstances and

          submission made on behalf of the parties and considering the

          remoteness of allegation which is quite vague and further

          considering the lack of substantive material against the

          petitioners and also considering the period of custody of the

          petitioners and submission of charge sheet, the petitioners are

          directed to be released on bail, on furnishing bail bonds of

          Rs.10,000/- (Rupees Ten Thousand Only) each with two sureties

          of the like amount each to the satisfaction of learned Chief

          Judicial Magistrate, Madhepura/concerned court, in connection

          with Murliganj P.S. Case No. 333/2025, subject to the

          conditions mentioned in Section 480 (3) of BNSS and also the

          following conditions :
           Patna High Court CR. MISC. No.82633 of 2025(3) dt.11-02-2026
                                                       4/4




                                             (i) One of the bailors will be a close

                                             relative of the petitioners.

                                             (ii) The petitioners will remain present on

                                             each and every date fixed by the below, if

                                             so required by the learned trial court.

                                             (iii) In case of absence on three

                                             consecutive dates or in violation of the

                                             terms of the bail, the bail bond of the

                                             petitioners will be liable to be cancelled

                                             by the court concerned.



                                               (Arun Kumar Jha, J)
V.K.Pandey/-

U      T


Continue reading with your account

Sign in to read the full judgment. It’s free.

Sign in to read

Checking your session…

For a signed copy suitable for filing, refer to the court's website.