Patna High Court

Randhir Sahni @ Randheer SahniversusThe State of Bihar

Decided: 25 February 2026
Disposal: BAIL GRANTED
Bench: CHANDRA SHEKHAR JHA

Holding

The court granted bail to the petitioner, Randhir Sahni.

Summary

Randhir Sahni was arrested in connection with a murder case (PS Bhagwanpur Case No.292 of 2024) under Sections 103(1) and 3(5) of the B.N.S. He has been in custody since 2 September 2025. The prosecution alleges that he, along with ten co‑accused, killed the informant’s brother‑in‑law using iron rods. The defence argued that the post‑mortem report showed only a single fatal head injury and some abrasions, creating doubt about the alleged assault, and that the investigation was already completed with a charge‑sheet filed, leaving no scope for evidence tampering. The State opposed bail. The court, noting the general nature of the assault allegation, the doubt raised by the medical evidence, the completed investigation, and the petitioner’s prolonged custody, ordered his release on bail with a bond of Rs.10,000 and two sureties, subject to conditions under Section 437(3) CrPC and Section 480(3) B.N.S.

Issues considered

Whether bail should be granted to the accused under Sections 103(1) and 3(5) of the B.N.S.
Whether the post‑mortem findings create reasonable doubt sufficient to justify bail
Whether the completion of investigation and filing of charge‑sheet precludes denial of bail

Legislation cited

B.N.S. — s. 480(3)
Code of Criminal Procedure — s. 437(3)

Subjects

bail
murder
post‑mortem
general allegation
investigation completed
CrPC
B.N.S.
Sections 103(1)
Section 3(5)

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.89815 of 2025
                    Arising Out of PS. Case No.-292 Year-2024 Thana- BHAGWANPUR District- Vaishali
                 ======================================================
                 Randhir Sahni @ Randheer Sahni S/O Jagarnath Sahni R/O- Village- Banthu,
                 Ward No.- 1, P.S.- Bhagwanpur, District- Vaishaili.
                                                                            ... ... Petitioner/s
                                                   Versus
                 The State of Bihar
                                                                     ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr. Janardan Prasad Singh, Adv
                 For the Opposite Party/s :       Mr. Nitya Nand Tiwary, APP
                 For the Informant        :       Mr. Ashok Kumar, Adv
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE CHANDRA SHEKHAR JHA
                                       ORAL ORDER

2   25-02-2026                  Heard the parties.

                                2. The accused/petitioner seeks bail in connection

                   with Bhagwanpur P.S. Case No.292 of 2024 registered for the

                   offences under Sections 103(1) and 3(5) of the B.N.S.

                                3. The accused/petitioner is named in the FIR and is

                   in custody since 02.09.2025.

                                4. Allegation against the petitioner is to commit

                   murder of brother-in-law (Bahnoi) of the informant along with

                   ten named co-accused persons by using iron rods.

                                5. It is submitted by learned counsel appearing for

                   petitioner that the allegation qua physical assault is appearing

                   very much general and omnibus against the petitioner and if

                   postmortem report of the deceased be taken into consideration
Patna High Court CR. MISC. No.89815 of 2025(2) dt.25-02-2026
                                            2/3




          then, allegation of indiscriminate assault by using iron rod by

          ten named accused persons, prima facie creates a doubt qua

          occurrence as alleged. It is submitted that upon postmortem ,

          only single injury was found upon head, which proved fatal

          beside some abrasion on back, which appears possible also due

          to falling on hard surface. While concluding argument, it is

          submitted that investigation of this case is already completed,

          for which, charge-sheet has been submitted and, as such, there

          is no chance of tampering with the evidence.

                       6. Learned APP opposed the prayer for grant of bail to

          the petitioner.

                       7. In view of aforesaid factual submissions and by

          taking note of fact as allegation qua physical assault appearing

          very much general and omnibus against the petitioner, which

          creates prima facie a doubt qua occurrence in view of available

          injuries through postmortem report, coupled with the fact that

          investigation of this case is already completed, where petitioner

          remains in custody since 02.09.2025, accordingly, the

          petitioner, above-named, is directed to be released on bail

          furnishing bail bond of Rs.10,000/- (Rupees Ten Thousand)

          with two sureties of the like amount each to the satisfaction of
               Patna High Court CR. MISC. No.89815 of 2025(2) dt.25-02-2026
                                                           3/3




                         the learned A.C.J.M.-VI, Vaishali at Hajipur in connection with

                         Bhagwanpur P.S. Case No.292 of 2024, subject to the

                         conditions as laid down under Section 437(3) of the Code of

                         Criminal Procedure (for short ‘CrPC’)/under Section 480(3) of

                         the BNSS.


                                               (Chandra Shekhar Jha, J)
S.Tripathi/-

U       T

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