Patna High Court

Dilip Sahani @ NiteshjiversusThe State of Bihar

Decided: 27 February 2026
Disposal: REJECTED
Bench: SATYAVRAT VERMA

Holding

The court denied bail to the petitioner.

Summary

The petitioner, Dilip Sahani, applied for regular bail in a case registered under the Unlawful Activities (Prevention) Act (UAPA) and the Arms Act. The charges include offences under Sections 10, 11, 13, 18B and 20 of the UAPA and Sections 25(1‑b)(a) and 26 of the Arms Act. The petitioner had previously sought bail in Cr. Misc. No. 66912 of 2024, which was rejected on 4‑October‑2024. The court examined the earlier order and found no new material or change in circumstances warranting a different decision. Consequently, the court rejected the current bail application, maintaining the earlier stance.

Issues considered

Whether bail should be granted to a person charged under Sections 10, 11, 13, 18B, 20 of the Unlawful Activities (Prevention) Act and Sections 25(1‑b)(a) and 26 of the Arms Act
Whether the prior rejection of bail precludes the grant of bail on a subsequent application

Legislation cited

Arms Act — s. 25(1-b)(a), 26
Unlawful Activities (Prevention) Act — s. 10, 11, 13, 18B, 20

Subjects

bail
UAPA
Arms Act
high court
denial of bail
criminal procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.85651 of 2025
                  Arising Out of PS. Case No.-157 Year-2017 Thana- INDUSTRIAL AREA District- Vaishali
                 ======================================================
                 Dilip Sahani @ Niteshji Son of Late Shivnandan Sahni Resident of Village-
                 Kajipur Thathan, P.S.- Hajipur Sadar, District- Vaishali

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr.Vasant Vikas
                 For the Opposite Party/s :       Mr. Chandra Bhushan Prasad, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
                                       ORAL ORDER

2   27-02-2026               1.    Heard learned counsel for the petitioner and

                   learned A.P.P. for the State, Sri Chandra Bhushan Prasad.

                             2.    The petitioner seeks bail in connection with

                   Industrial Area P.S. Case No.157/2017, registered for the

                   offence punishable under Sections 10, 11, 13, 18B & 20 of

                   Unlawful (Activities) Prevention Act Act & Sections 25(1-b)a &

                   26 of the Arms Act.

                             3.    Learned counsel for the petitioner submits that this

                   is the second attempt of the petitioner to seek regular bail. It is

                   next submitted that petitioner had earlier moved before this

                   Court seeking regular bail by filing Cr. Misc No. 66912 of 2024

                   and the same came to be rejected by an order dated 4-10-2024.

                             4.    The Court has perused the order dated 4-10-2024

                   in Cr. Misc No. 66912 of 2024 as such is not inclined to release
              Patna High Court CR. MISC. No.85651 of 2025(2) dt.27-02-2026
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                        the petitioner on bail.

                                 5.     Accordingly, the prayer for bail of the petitioner is

                        rejected.



                                                  (Satyavrat Verma, J)
Sumit/-

U         T

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