Patna High Court

Lalo DeviversusThe State of Bihar

Decided: 24 March 2026
Disposal: DISMISSED
Bench: SANDEEP KUMAR

Holding

The bail application was dismissed, denying the petitioner any relief.

Summary

Lalo Devi, the petitioner, applied for bail in a case registered under multiple sections of the Indian Penal Code, the Arms Act and the Unlawful Activities (Prevention) Act, alleging involvement in Naxal activities. The prosecution alleged that an AK-47, an AK-56 and cartridges were recovered from her possession. She has been in judicial custody since 29 August 2025. The learned judge examined the seriousness of the offences, the nature of the weapons recovered and the alleged Naxal links. Concluding that the circumstances did not warrant bail, the court dismissed the bail application.

Issues considered

Whether bail should be granted to the petitioner in view of the alleged Naxal involvement and recovery of firearms.

Legislation cited

Arms Act — s. 25(1-AA), 26, 35
Indian Penal Code — s. 120(B), 121, 147, 148, 149, 216, 353
Unlawful Activities (Prevention) Act — s. 13, 16, 17, 18, 19, 20, 38, 39

Subjects

bail
Naxal
firearms
IPC
Arms Act
UAPA
high court

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.88359 of 2025
                       Arising Out of PS. Case No.-111 Year-2022 Thana- IMAMGANJ District- Gaya
                 ======================================================
                 Lalo Devi son of Ramnaresh Bharti Village- Dukhatpur PS -Banke Bazar Dist
                 -Gaya Ji

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr.Vijay Kumar
                 For the Opposite Party/s :       Mr.Mohammad Sufyan
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
                                       ORAL ORDER

4   24-03-2026                    Heard the parties.

                                 2. The petitioner seeks bail in connection with

                   Imamganj P.S. Case No. 111 of 2022 registered for the offence

                   under Sections 147, 148, 149, 353, 121, 216, 120(B) of the

                   Indian Penal Code, under Sections 25(1-AA), 26, 26, 35 of the

                   Arms Act and under Sections 13, 16, 17, 18, 19, 20, 38, 39 of

                   the UAP Act.

                                 3. As per the prosecution case, the recovery is of one

                   AK-47 and AK-56 along with cartridges from the petitioner.

                                 4. The petitioner is in custody since 29.08.2025 and

                   from the recovery it appears that she is involved in naxal

                   activities.

                                 5. In view of the above, this Court is not inclined to

                   grant bail to the petitioner.
          Patna High Court CR. MISC. No.88359 of 2025(4) dt.24-03-2026
                                                      2/2




                                 6. Accordingly, this application is dismissed.



                                                            (Sandeep Kumar, J)
Vikas/-

U

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