Patna High Court

Sachin Kumar @ Sachin RanjanversusThe State of Bihar

Decided: 16 January 2026
Disposal: BAIL GRANTED
Bench: R P MISHRA

Holding

The court held that bail should be granted to the petitioner, ordering his release on bail with the prescribed bond and sureties.

Summary

The petitioner, Sachin Kumar, applied for bail in a case (Halsi P.S. Case No. 163 of 2025) under Section 309(4) of the B.N.S., 2023, alleging that he was falsely implicated based on a self‑confessional statement that lacks evidentiary value. The prosecution alleged that six unknown persons snatched a bag containing SIM cards, mobile phones, cash and documents, but no incriminating items were recovered from the petitioner or his residence, and no T.I.P. was conducted. The petitioner highlighted non‑compliance with Section 103 of the B.N.S.S., creating reasonable doubt, and noted that a co‑accused had already been granted bail. The State opposed bail. After considering the facts, the court ordered the petitioner’s release on bail with a bond of Rs.15,000 and two sureties of the same amount.

Issues considered

Whether bail should be granted to the petitioner under Section 309(4) of the B.N.S., 2023 in view of the alleged facts.
Whether the self‑confessional statement, lacking evidentiary value, and the absence of recovered stolen articles justify granting bail.
Whether non‑compliance with Section 103 of the B.N.S.S. creates reasonable doubt sufficient to warrant bail.

Legislation cited

B.N.S., 2023 — s. 309(4)
B.N.S.S. — s. 103

Subjects

bail
Section 309(4)
self‑confessional statement
Section 103
judicial custody
criminal procedure
reasonable doubt

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.89537 of 2025
                       Arising Out of PS. Case No.-163 Year-2025 Thana- HALSI District- Lakhisarai
                 ======================================================
                 Sachin Kumar @ Sachin Ranjan S/o- Yugeshwar Mahto @ Yogeshwar Mahto
                 Resident of Village- Kakan, P.S. and District- Jamui.
                                                                              ... ... Petitioner/s
                                                     Versus
                 The State of Bihar
                                                                       ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :        Mr.Md Irshad, Advocate
                 For the Opposite Party/s :        Mr.Bishweshwar Ram, A.P.P.
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE RUDRA PRAKASH
                 MISHRA
                                       ORAL ORDER

2   16-01-2026                  Heard learned counsel for the petitioner and learned

                   APP for the State.

                                2. The petitioner seeks bail in connection with Halsi P.S.

                   Case No. 163 of 2025 instituted for the offences under Section

                   309(4) of the B.N.S., 2023.

                                3. As per prosecution case, six unknown miscreants,

                   who were on two motorcycles, surrounded the informant on the

                   point of fire arms and snatched his bag containing 40 SIM Cards,

                   07 Keypad mobile phones and some other devices, Rs. 6,500/-

                   cash as also documents of the motorcycle.

                                4. Learned counsel for the petitioner submits that the

                   petitioner is innocent and has committed no offence as alleged

                   against him and has falsely been implicated in the present case.

                   The name of the petitioner has transpired in this case only on self

                   confessional statement before the Police, which has no evidentiary
           Patna High Court CR. MISC. No.89537 of 2025(2) dt.16-01-2026
                                                       2/2




                     value. He further submits that nothing incriminating/stolen article

                     has been recovered from the conscious possession of the petitioner

                     or from his house. No T.I.P. has also been conducted in this case.

                     The petitioner has no concern with the alleged occurrence. There

                     is a non-compliance of Section 103 of the B.N.S.S. which creates a

                     serious doubt in the prosecution case. The other co-accused has

                     been granted bail by this Court vide order dated 28.11.2025 passed

                     in Criminal Miscellaneous No. 68074 of 2025. The petitioner has

                     two criminal antecedents and is languishing in judicial custody

                     since 12.08.2025 without any rhymes or reason.

                                  5. On the other hand, learned A.P.P. for the State has

                     vehemently opposed the prayer for grant of bail to the petitioner.

                     6. Having heard rival contention of both the parties and

                     considering the entire facts and circumstances of the case as also

                     taking into account the period of custody of the petitioner, let the

                     petitioner, abovenamed, be released on bail on furnishing bail

                     bonds of Rs.15,000/- (Rupees Fifteen Thousand) with two sureties

                     of the like amount each to the satisfaction of Court

                     below/concerned Court in connection with Halsi P.S. Case No. 163

                     of 2025.


                                           (Rudra Prakash Mishra, J)
manish/-
U      T

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