Patna High Court

Ramayan Sahni @ Ramayan ChaudharyversusThe State of Bihar

Decided: 10 February 2026
Disposal: BAIL GRANTED
Bench: PRABHAT KUMAR SINGH

Holding

The court held that, given the petitioner's clean antecedent and lack of direct evidence, bail was permissible under Section 482(2) of the Bharatiya Nagarik Suraksha Sanhita.

Summary

The petitioner, Ramayan Sahni, sought bail in a case where he was implicated through confessional statements of co-accused for offences under IPC sections 302, 201 and 34. He argued that he was not named in the FIR and there was no direct material linking him to the murder of the informant's daughter. The State opposed the bail, contending the seriousness of the charges. The court noted the petitioner's clean antecedent, the absence of evidence beyond the confessional statements, and the fact that co-accused had already been granted bail. Accordingly, the court ordered bail on a bond of Rs.10,000 with two sureties, subject to conditions under Section 482(2) of the Bharatiya Nagarik Suraksha Sanhita, 2023.

Issues considered

Whether bail can be granted to the petitioner under Section 482(2) of the Bharatiya Nagarik Suraksha Sanhita despite allegations under IPC sections 302, 201 and 34.
Whether the confessional statements of co-accused constitute sufficient basis to deny bail.

Legislation cited

Bharatiya Nagarik Suraksha Sanhita — s. 482(2)
Indian Penal Code — s. 201, 302, 34

Subjects

bail
IPC
Section 302
Section 201
Section 34
confessional statement
clean antecedent
Bharatiya Nagarik Suraksha Sanhita
criminal procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.88629 of 2025
                   Arising Out of PS. Case No.-191 Year-2024 Thana- NAUTAN District- West Champaran
                 ======================================================
                 Ramayan Sahni @ Ramayan Chaudhary Son of Late Jokhu Sahni Resident of

                 Village - Dakshni Telhua Pokhra Tola, Ward No.- 07, P.S.- Nautan, District -

                 West Champaran.



                                                                                  ... ... Petitioner/s

                                                       Versus

                 The State of Bihar



                                                                            ... ... Opposite Party/s

                 ======================================================
                 Appearance :

                 For the Petitioner/s       :     Mr. Umesh Kumar Gupta, Advocate

                 For the Opposite Party/s :       Mr. Bhanu Pratap Singh, APP

                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE PRABHAT KUMAR SINGH
                                       ORAL ORDER

2   10-02-2026                          Heard learned counsel for the petitioner and the

                   State .

                                 2. Petitioner apprehends his arrest in a case registered

                   for the offence punishable under sections 302, 201 and 34 of the

                   IPC .

                                 3 . As per FIR, all the named accused persons

                   including this petitioner killed the daughter of the informant and

                   cremated her body .
Patna High Court CR. MISC. No.88629 of 2025(2) dt.10-02-2026
                                            2/3




                       4. It is submitted on behalf of the petitioner that

          petitioner is not named in the FIR. It is the specific case of the

          informant that named accused persons killed the daughter of

          informant. The name of the petitioner transpired during course

          of investigation in the confessional statement of other co-

          accused persons. Save and except, confessional statement, there

          is no other material on record to show the complicity of this

          petitioner in the alleged occurrence . There is no allegation

          against the petitioner that he has participated in the murder of

          the deceased. Petitioner claims clean antecedent. Similarly co-

          accused persons have already been granted bail by this Hon’ble

          Court vide order dated 17.11.2025 in Cr. Misc. No. 76443 of

          2025 .

                       5 . Learned counsel for the State opposes the bail

          petition .

                        6. Considering the aforesaid facts, clean antecedent

          of the petitioner and other circumstances of the case , in the

          event of arrest or surrender within eight weeks from today, let

          the petitioner, as named above, be enlarged on bail on furnishing

          bail bond of Rs.10,000/-(ten thousand) with two sureties of the

          like amount each to the satisfaction of the learned Chief Judicial

          Magistrate West champaran Bettiah in connection with Nautan
            Patna High Court CR. MISC. No.88629 of 2025(2) dt.10-02-2026
                                                        3/3




                      P.S. Case No. 191 of 2024 , subject to the conditions laid down

                      under section 482(2) of the Bharatiya Nagarik Suraksha Sanhita,

                      2023 .



                                            (Prabhat Kumar Singh, J)
Koushik/-

U      T

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