Patna High Court

Sata Yadav @ Satyanarayan YadavversusThe State of Bihar

Decided: 22 April 2026
Disposal: BAIL GRANTED
Bench: ALOK KUMAR SINHA

Holding

The court granted anticipatory bail to the petitioners subject to specified conditions.

Summary

The petitioners, Sata Yadav and Sonu Yadav, sought anticipatory bail fearing arrest in a case (Rajoun PS Case No. 291 of 2020) involving offences under Sections 147, 149, 307, 341, 323, 504 and 506 of the IPC. They claimed they were falsely implicated due to a land dispute and asserted no criminal antecedent. The State opposed the bail, but the court noted the absence of any specific allegation that the petitioners assaulted the informant and that they were only alleged members of a gang. Considering their clean record, the court granted anticipatory bail under Section 438(2) of the CrPC and Section 482(2) of the Bharatiya Nagarik Suraksha Sanhita, 2023, subject to a bail bond of Rs.10,000 each, two sureties, cooperation with investigation, and verification of criminal antecedents. The order also provided for possible cancellation of bail if antecedents are concealed.

Issues considered

Whether anticipatory bail should be granted to the petitioners under Section 438 CrPC and Section 482(2) B.N.S. 2023
Whether the petitioners pose a risk of absconding, tampering with evidence or influencing witnesses
Whether the petitioners have any undisclosed criminal antecedents

Legislation cited

Bharatiya Nagarik Suraksha Sanhita, 2023 — s. 482
Code of Criminal Procedure — s. 438
Indian Penal Code — s. 147, 149, 307, 323, 341, 504, 506

Subjects

anticipatory bail
Section 438 CrPC
Bharatiya Nagarik Suraksha Sanhita
land dispute
gang affiliation
IPC offences
bail conditions

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.8924 of 2026
                        Arising Out of PS. Case No.-291 Year-2020 Thana- RAJAON District- Banka
                 ======================================================
           1.     Sata Yadav @ Satyanarayan Yadav S/o Fakir Yadav R/o Village -
                  Sujalkorama, P.S - Rajoun, District - Banka
           2.    Sonu Yadav S/o Munni Yadav R/o Village - Sujalkorama, P.S - Rajoun,
                 District - Banka

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr.Dhananjay Kumar Pandey
                 For the Opposite Party/s :       Mr.Rajendra Nath Jha
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ALOK KUMAR SINHA
                                       ORAL ORDER

3   22-04-2026                    Heard learned counsel for the petitioners and learned

                   A.P.P. for the State.

                                2. The petitioners apprehend their arrest in a case

                   registered for the offence punishable under Sections 147, 149,

                   307, 341, 323, 504 and 506 of the IPC, in connection with

                   Rajoun P.S.Case No. 291 of 2020.

                                3. Learned counsel for the petitioner submits that the

                   petitioner is innocent and have falsely been implicated in the

                   present case. Both the petitioners are relatives and there are

                   some land dispute between the parties.

                                4. Learned A.P.P. for the State opposes the prayer for
Patna High Court CR. MISC. No.8924 of 2026(3) dt.22-04-2026
                                            2/3




          anticipatory bail of the petitioner.

                        5. Considering the fact that there is no specific

          allegation against the petitioners of having assaulted the

          informant and that they are alleged to be merely members of the

          gang and also that the petitioners do not have any criminal

          antecedent, I am inclined to grant privilege of anticipatory bail

          to the petitioners..

                        6. Let the petitioners, as named above, in the event of

          their arrest or surrender within four weeks from today, be

          enlarged on bail on furnishing bail bond of Rs.10,000/- (Rupees

          Ten Thousand) each, with two sureties of the like amount each

          to the satisfaction the learned trial court in connection with

          Rajoun P.S.Case No. 291 of 2020, subject to the conditions laid

          down under section 438(2) of the Code of Criminal

          Procedure/Section 482(2) of the Bharatiya Nagarik Suraksha

          Sanhita, 2023 and subject to further condition that :-

                        (i) the petitioners shall co-operate in the investigation/

          trial. (ii)

                        the learned court would, however, verify the criminal

          antecedents of the petitioners and in case it is found that the

          petitioners have concealed their criminal antecedents, the court

          below shall take step for cancellation of bail bond of the
           Patna High Court CR. MISC. No.8924 of 2026(3) dt.22-04-2026
                                                       3/3




                     petitioners. However, it is expected that the verification process

                     would be done expeditiously without causing any delay.


                                              (Alok Kumar Sinha, J)

HR/-

U      T

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