Patna High Court
Ranjan Barnwal @ Ranjan KumarversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- SONI SHRIVASTAVA
Holding
The Court held that bail should be granted as the allegations are not serious, there is no injury, and the delay in filing the FIR indicates lack of urgency.
Summary
The petitioner, Ranjan Barnwal, sought bail after an FIR was lodged alleging that he and others recorded a domestic dispute and threatened to publicise the video, invoking sections 79, 296, 64(1), 61(2) and 62 of the Bharatiya Nagarik Suraksha Sanhita. The FIR was filed two days after the alleged incident, and the informant admitted being the second wife of the husband involved. The petitioner argued that the delay indicated lack of urgency, there was no injury or serious allegation, and he had no prior criminal record. The State opposed bail, relying on the FIR allegations. The Court, noting the delay, the absence of serious harm, and the petitioner's clean record, granted bail on a bond of Rs. 10,000 with two sureties, subject to Section 438(2) of the Cr.P.C. and Section 482(2) of the BNSS.
Issues considered
- Whether the petitioner is entitled to bail despite the FIR alleging offences under the BNSS.
- Whether the two‑day delay in lodging the FIR affects the merit of the bail application.
Legislation cited
- Bharatiya Nagarik Suraksha Sanhita, 2023 — s. 296, 482(2), 61(2), 62, 64(1), 79
- Code of Criminal Procedure, 1973 — s. 438(2)
Subjects
- bail
- delay in FIR
- domestic dispute video
- Bharatiya Nagarik Suraksha Sanhita
- Criminal Procedure Code
- Section 438
- Section 482
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.88219 of 2025
Arising Out of PS. Case No.-449 Year-2025 Thana- JHAJHA District- Jamui
======================================================
Ranjan Barnwal @ Ranjan Kumar S/o Munna Barnwal R/o Village - Dhamna,
P.S - Jhajha, District - Jamui
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Ms. Sanju Singh, Advocate
For the Opposite Party/s : Mr. Sanjay Kumar Singh, APP
======================================================
CORAM: HONOURABLE JUSTICE SMT. SONI SHRIVASTAVA
ORAL ORDER
2 15-01-2026 Heard Ms. Sanju Singh, learned counsel for the
petitioner and Mr. Sanjay Kumar Singh, learned A.P.P. for the
State.
2. The petitioner apprehends his arrest in a case
registered for the offences punishable under Section 79, 296,
64(1), 61(2), 62 of B.N.S.
3. The allegation in the First Information Report is that
while the informant was having an altercation with her husband’s
first wife, the accused persons including the present petitioner
were making video of the said dispute and were threatening to
make it viral and also indulged in abusing her.
4. Learned counsel for the petitioner submits at the
outset that the present F.I.R. was lodged after delay of two days
without any plausible explanation given by the prosecution
inasmuch as, while the present occurrence took place on
13.09.2025, the F.I.R. was lodged on 15.09.2025. It has further
been submitted that the informant herself admits that she is the
second wife of Dilip Barnwal and the only allegation attributed to
Patna High Court CR. MISC. No.88219 of 2025(2) dt.15-01-2026
2/2
the petitioner and others is that they were engaged in making some
videos of physical altercation with her husband’s first wife causing
her severe humiliation.
5. Learned APP for the State opposed the prayer for
bail on the basis of allegations made in the First Information
Report.
6. Taking into consideration the facts and considering
the fact that no serious allegation has been alleged against the
present petitioner and no injury etc., has also been caused in the
entire incident, coupled with the fact that there is also a delay in
the F.I.R. indicating the lodging of the same after due thought and
deliberation, let the above named petitioner, who has no criminal
antecedent, be released on bail, in the event of his arrest or
surrender before the learned Court below within a period of four
weeks from today, on furnishing bail bond of Rs. 10,000/- (Rupees
Ten Thousand) with two sureties of the like amount each to the
satisfaction of the learned Court below where the case is
pending/successor Court in connection with Jhajha P.S. Case No.
449 of 2025, subject to the condition as laid down under Section
438 (2) of the Cr.P.C/ Section 482 (2) of the Bharatiya Nagarik
Suraksha Sanhita (BNSS), 2023.
(Soni Shrivastava, J)
anand/-
U T
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