Patna High Court

Rishi Kumar MandalversusThe State of Bihar

Decided: 19 March 2026
Disposal: DISMISSED
Bench: SANDEEP KUMAR

Holding

The Court denied bail, holding that the seriousness of the allegations warranted continued detention.

Summary

The petitioner, Rishi Kumar Mandal, was arrested in connection with a case registered under Sections 126(2), 109, 118(2), 352, 351(1), 190 of the Bihar Penal Code (BNS) and Section 27 of the Arms Act, alleging that he and others fired upon a victim causing injuries. He has been in custody since 30 September 2025 and applied for regular bail. The prosecution contended that the offences are serious and involve the use of firearms, justifying continued detention. The Court examined the nature of the allegations and the risk to public order and the victim. Considering the seriousness of the charges, the Court was not inclined to grant bail and dismissed the application, noting that the petitioner may re‑apply if the trial is delayed due to prosecution fault.

Issues considered

Whether regular bail should be granted to the petitioner in a case involving alleged firing on a victim under the specified sections of the Bihar Penal Code and the Arms Act.

Legislation cited

Arms Act — s. 27
Bihar Penal Code (BNS) — s. 109, 118(2), 126(2), 190, 351(1), 352

Subjects

bail
regular bail
criminal procedure
Arms Act
serious offences
custody
trial delay

Judgment

                       IN THE HIGH COURT OF JUDICATURE AT PATNA
                               CRIMINAL MISCELLANEOUS No.86685 of 2025
                       Arising Out of PS. Case No.-146 Year-2025 Thana- SABAUR District- Bhagalpur
                  ======================================================
                  Rishi Kumar Mandal Son of Shashi Bhushan Mandal R/o Village- Lailakh,
                  P.S.- Sabour, Dist.- Bhagalpur
                                                                        ... ... Petitioner/s
                                                 Versus
                  The State of Bihar Bihar
                                                                 ... ... Opposite Party/s
                  ======================================================
                  Appearance :
                  For the Petitioner/s     :       Mr.Rajive Ranjan Singh
                  For the Opposite Party/s :       Mr.Jagdhar Prasad
                  ======================================================
                  CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
                                        ORAL ORDER

3    19-03-2026                    Heard the parties.

                                 2. The petitioner seeks regular bail in connection with

                    Sabour P.S. Case No. 146 of 2025 registered for the offence

                    under Sections 126(2), 109, 118(2), 352, 351(1), 190 of BNS

                    and under Section 27 of the Arms Act.

                                 3. As per the prosecution case, the petitioner and

                    others are said to have fired upon the victim causing injuries.

                                 4. The petitioner is in custody since 30.09.2025.

                                 5. Considering the nature of allegations levelled

                    against the petitioner, this Court is not inclined to grant bail to

                    the petitioner.

                                 6. Accordingly, this application is dismissed.

                                 7. If the trial of the petitioner is delayed due to fault of

                    the prosecution then the petitioner may renew his prayer.


                                                            (Sandeep Kumar, J)
Vikas/-
U

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