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Patna High Court

Ranjan Barnwal @ Ranjan KumarversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

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

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
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                      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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