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Patna High Court

Pappu Singh @ Pramod SinghversusThe State of Bihar

Decided
Disposal
BAIL REJECTED

Holding

Bail is denied as there is no fresh ground and the trial is at an advanced stage.

Summary

Pappu Singh was charged under IPC sections 341, 307, 302, 506, 34 and Section 27 of the Arms Act. He has been in judicial custody since 11 January 2024. After an earlier bail denial, he sought bail again, arguing that only nine of fourteen prosecution witnesses had been examined. The State opposed, relying on a 2024 Supreme Court decision that bail is rarely granted once trial of serious offences has commenced. The Patna High Court found no fresh ground for bail and noted the trial was at an advanced stage, consequently rejecting the bail application and directing the trial court to conclude the trial within three months, with a provision to re‑apply thereafter.

Issues considered

  • Whether bail can be granted at an advanced stage of trial for serious offences such as murder and attempted murder.
  • Whether any fresh ground exists to justify granting bail despite the trial’s progress.
  • Whether the Supreme Court precedent in X vs. State of Rajasthan (2024) is applicable to deny bail.

Legislation cited

Subjects

  • bail
  • criminal procedure
  • serious offences
  • trial stage
  • Indian Penal Code
  • Arms Act
  • high court
  • pre‑trial detention

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.89902 of 2025
                     Arising Out of PS. Case No.-16 Year-2024 Thana- GOPALPUR District- Bhagalpur
                 ======================================================
                 Pappu Singh @ Pramod Singh S/o Late Shyamsunder Singh R/V- Navtolia,
                 Latra, PS- Gopalpur, Dist- Bhagalpur


                                                                                  ... ... Petitioner/s
                                                       Versus

                 The State of Bihar


                                                        ... ... Opposite Party/s
                 ======================================================

                 Appearance :
                 For the Petitioner/s     :       Mr. Anuj Kumar, Advocate
                 For the Opposite Party/s :       Mr. Aditya Narayan Singh.1, APP
                 ======================================================

                 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 Gopalpur

                   P.S. Case No. 16 of 2024, Sessions Trial No. 496 of 2024

                   instituted for the offences under Sections 341, 307, 302, 506, 34

                   of the Indian Penal Code and Section 27 of the Arms Act.

                             3. Earlier vide order dated 30.04.2025 passed in Cr.

                   Misc. No. 5709 of 2025 regular bail of the petitioner was

                   rejected by this Court considering the stage of the trial, nature of

                   accusation and gravity of offence. However, the liberty was

                   granted to the petitioner to renew his prayer for bail if the trial is
Patna High Court CR. MISC. No.89902 of 2025(2) dt.16-01-2026
                                            2/3




          not concluded within a period of six months.

                   4. Learned counsel for the petitioner submits that the

          petitioner is languishing in judicial custody since 11.01.2024

          without any rhymes or reason. Learned counsel further

          submitted that out of total 14 prosecution witnesses, only 9 have

          been examined till date.

                   5. Learned APP for the State opposes the prayer for

          grant of bail. Learned APP for the State relied upon a decision

          of the Hon’ble Apex Court reported in 2024 SCC OnLine SC

          3539 (X. vs. State of Rajasthan & Anr.), wherein in paragraph

          no. 14, the Hon’ble Apex Court has held has under:

                          “14. Ordinarily in serious offences like rape,

                          murder, dacoity, etc., once the trial commences and

                          the prosecution starts examining its witnesses, the

                          Court, be it the Trial Court or the High Court

                          should be loath in entertaining the bail application

                          of the accused.”

                   6. There is no fresh ground to consider the bail petition

          of the petitioner as also the trial is at the advanced stage.

                   7. In view of the above, the prayer for bail of the

          petitioner is again rejected with a direction to the court below to

          expedite the trial and conclude the same expeditiously
           Patna High Court CR. MISC. No.89902 of 2025(2) dt.16-01-2026
                                                       3/3




                     preferably within a period of three months from today. If the

                     trial is not concluded within the period of three months, as

                     stated above, the petitioner will be at liberty to renew his prayer

                     before the court below.



                                           (Rudra Prakash Mishra, J)
Alok Verma/-

U      T


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