Patna High Court

Dharmendra Kumar @ DomaversusThe State of Bihar

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

Holding

The bail application was dismissed.

Summary

The petitioner, Dharmendra Kumar, applied for bail in a case registered under Section 392 of the Indian Penal Code for the alleged looting of a Scorpio vehicle. The prosecution alleged that unknown criminals committed the theft and that the petitioner’s name appeared in the self‑inculpatory statements of co‑accused Chandan Kumar and Shlok Kumar, from whom the vehicle was recovered. The petitioner has been in custody since 26 September 2025 and has thirteen prior criminal antecedents. The court considered the seriousness of the robbery charge, the petitioner’s involvement as indicated by co‑accused statements, and his extensive criminal record. Concluding that these factors outweighed the presumption of innocence, the court declined to grant bail and dismissed the application.

Issues considered

Whether bail should be granted to the petitioner in a case of robbery under Section 392 IPC given the self‑inculpatory statements of co‑accused.
Whether the petitioner’s extensive criminal antecedents justify denial of bail.

Legislation cited

Indian Penal Code — s. 392

Subjects

bail
robbery
Section 392 IPC
criminal antecedents
self‑inculpatory statement

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.88826 of 2025
                   Arising Out of PS. Case No.-15 Year-2020 Thana- MAHESHKHUNT District- Khagaria
                 ======================================================
                 Dharmendra Kumar @ Doma Son of Raja Ram Singh Resident of village -
                 Janardanpur, P.S.- Fatuha, District - Patna.

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :     Mr.Saurav Anand
                 For the Opposite Party/s :     Mr.Sanjay Kumar Tiwary
                                                Mr. Jharkhandi Upadhyay
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
                                       ORAL ORDER

3   24-03-2026                    Heard the parties.

                                2. The petitioner seeks bail in connection with

                   Maheshkhut P.S. Case No. 15 of 2020 registered for the offence

                   under Section 392 of the Indian Penal Code.

                                3. As per the prosecution case, unknown criminals are

                   said to have committed loot of a scorpio vehicle.

                                4. The name of the petitioner has come in the self-

                   inculpatory statement of co-accused Chandan Kumar and Shlok

                   Kumar from whom the looted Scorpio vehicle has been

                   recovered.

                                5. The petitioner is in custody since 26.09.2025 and

                   he has 13 criminal antecedents also.

                                6. In view of the above, this Court is not inclined
          Patna High Court CR. MISC. No.88826 of 2025(3) dt.24-03-2026
                                                      2/2




                    grant to the petitioner.

                                 7. Accordingly, this application stands dismissed.



                                                             (Sandeep Kumar, J)
Vikas/-

U

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