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Patna High Court

Munna Khan @ T. T. @ Munna Mian @ Mannu KhanversusThe State of Bihar

Decided
Disposal
ALLOWED

Holding

The petitioner is entitled to regular bail as the prosecution failed to produce concrete evidence linking him to the alleged human trafficking offence.

Summary

Munna Khan was arrested in connection with PS‑Pathkhauli Case No.213 of 2025 for alleged offences under Sections 143, 61(2)(3) and 3(5) of the B.N.S., 2023, with the prosecution alleging his participation in human trafficking. The petitioner contended that he was falsely implicated, noting the absence of any victim statement, lack of a specific complaint, and his clean criminal record, having been in judicial custody since 11‑Oct‑2025. The State opposed the bail application, relying on the seriousness of the alleged trafficking offences. The Court, after hearing both sides, observed that the prosecution had not produced any concrete evidence linking the petitioner to a specific victim and that the petitioner had no prior convictions. Considering these circumstances, the Court deemed that the petitioner was entitled to regular bail. Consequently, the petitioner was ordered to be released on bail upon furnishing a bond of Rs.10,000 with two sureties of equal amount.

Issues considered

  • Whether the petitioner is entitled to regular bail despite allegations of human trafficking under the B.N.S., 2023.

Legislation cited

Subjects

  • regular bail
  • human trafficking
  • B.N.S. 2023
  • criminal procedure
  • no prior conviction
  • bail bond

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.89598 of 2025
                 Arising Out of PS. Case No.-213 Year-2025 Thana- PATKHAULI District- West Champaran
                 ======================================================
                 Munna Khan @ T. T. @ Munna Mian @ Mannu Khan S/o- Hadish Miya R/v-
                 Kharpokhra, P.S. Bagaha District- West champaran

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr. Bimlesh Kumar Pandey, Advocate
                 For the Opposite Party/s :      Mr. Brajendra Nath Pandey, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ASHOK KUMAR PANDEY
                                       ORAL ORDER

2   15-01-2026                  Heard learned counsel for the petitioner and Mr.

                   Brajendra Nath Pandey, learned APP for the State.

                                2. The petitioner has prayed for regular bail in

                   connection with Pathkhauli P.S. Case No. 213 of 2025 registered

                   for the offence punishable under Sections 143, 61(2) (3) and 3(5)

                   of the B.N.S., 2023.

                                3. The case of the prosecution in short is that the

                   petitioner along with others are indulged in human trafficking.

                                4. Learned counsel appearing on behalf of the petitioner

                   has submitted that petitioner is innocent and has committed no

                   offence. He has been falsely implicated in this case. Learned

                   counsel for the petitioner submits that from perusal of the FIR, it

                   is not clear as to whom the petitioner has trafficked. A general

                   story has been created that the petitioner and others are indulged
            Patna High Court CR. MISC. No.89598 of 2025(2) dt.15-01-2026
                                                        2/2




                      in human trafficking. There is no complaint from anybody and

                      from perusal of the order of the learned trial court also, it

                      transpires that during the course of investigation, no victim has

                      given her statement regarding the alleged occurrence. Moreover,

                      a statement has been made in para 3 of the petition that petitioner

                      has no criminal antecedent and he is languishing in judicial

                      custody since 11.10.2025.

                                   5. The application for bail is opposed by learned APP

                      for the State.

                                   6. Having heard learned counsel for the parties and

                      considering the facts and circumstances of the case, this Court is

                      inclined to enlarge the petitioner on bail.          The above named

                      petitioner is directed to be enlarged on bail on furnishing bail

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

                      the like amount each to the satisfaction of the learned Additional

                      Chief Judicial Magistrate 1st Class, Bagaha, West Champaran in

                      connection with Pathkhauli P.S. Case No. 213 of 2025.



                                            (Ashok Kumar Pandey, J)
durgesh/-

U      T


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