Patna High Court
Satish Mandal @ Baba @ Mandal @ Raju BhuiyanversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- RAJESH KUMAR VERMA
Holding
Bail was granted to the petitioner on the condition of a Rs 10,000 bond and compliance with stipulated conditions.
Summary
The petitioner, Satish Mandal, was arrested on 5 August 2025 in connection with a bomb‑explosion case (Sherghati PS Case No.568/2023) alleging offences under IPC sections 307, 427/34 and Explosive Substances Act sections 3, 4 and 5. The FIR did not name him; his alleged involvement emerged only from the confessional statement of co‑accused Adil Khan, while other co‑accused (Imran Khan, Devanand Das) were not charged. The petitioner sought bail, arguing that the reliance on a co‑accused’s confession without his name in the FIR was insufficient for continued detention. The State opposed bail, highlighting the petitioner’s nine other pending cases and his criminal antecedent. The Court, noting that the chargesheet was filed against him based solely on the co‑accused’s statement and that bail had been granted to other co‑accused, ordered his release on bail with a bond of Rs 10,000 and specific conditions, including cooperation with the trial and non‑tampering with evidence.
Issues considered
- Whether bail should be granted to an accused not named in the FIR but implicated through a co‑accused’s confessional statement.
- Whether the petitioner’s multiple pending criminal cases and alleged antecedents preclude bail.
Legislation cited
- Explosive Substances Act — s. 3, 4, 5
- Indian Penal Code — s. 307, 34, 427
Subjects
- bail
- IPC
- Explosive Substances Act
- confessional statement
- co‑accused
- criminal antecedent
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.90316 of 2025
Arising Out of PS. Case No.-568 Year-2023 Thana- SHERGHATI District- Gaya
======================================================
Satish Mandal @ Baba @ Mandal @ Raju Bhuiyan S/o Mannu Mandal @
Manu Bhuiyan @ Karu Mandal @ Karu Bhuiyan Resident of Village-
Patthalkati, P.S.- Sherghati, District- Gaya
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr.Paras Nath, Advocate
For the Opposite Party/s : Mr.Anil Kumar,APP
======================================================
CORAM: HONOURABLE MR. JUSTICE RAJESH KUMAR VERMA
ORAL ORDER
2 15-01-2026 Heard Mr.Paras Nath, learned counsel for the
petitioner and Mr.Anil Kumar, learned Additional Public
Prosecutor for the State.
2. The petitioner seeks bail, who is in custody since
05.08.2025 in connection with Sherghati (Dobhi) P.S. Case
No.568/2023, dated 31.05.2023 registered for the offences
punishable under Sections 307,427/34 of IPC and Sections 3/4/5
of Explosive Substance Act.
3. As per the prosecution case, on 31-05-2023 about
2:48 AM unknown persons exploded bomb with intention to kill
the informant and as a result of explosion damaged the window
and door of the informant's room. It is further alleged there in
that on earlier occasion miscreants had demanded rangdari.
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4. Learned counsel appearing for the petitioner
submits that the petitioner is not named in the FIR. The name of
the petitioner has been transpired during investigation on the
basis of the confessional statement of co-accused person,
namely, Adil Khan. From a bare perusal of the FIR it appears
that the informant stated in the FIR that he saw two accused
persons, namely, Imran Khan and Devanand Das at the time of
occurrence but they have not been sent up for trial by the
prosecution and co-accused person, namely, Adil Khan, who has
confessed the name of the petitioner, has been granted bail by a
Coordinate Bench of this Hon’ble Court vide order dated
04.04.2024 passed in Cr. Misc. No.24378 of 2024, and another
co-accused person, namely, Mahtab Khan has also been granted
bail by a Coordinate Bench of this Hon’ble Court vide order
dated 22.02.2024 passed in Cr. Misc. No.9637 of 2024. The
police, after investigation, submitted chargesheet against the
petitioner and the petitioner is in custody since 05.08.2025.
5. Learned APP for the State has opposed the prayer
for bail of the petitioner and submits that the petitioner carries
nine more cases other than the present one, as mentioned in
para-3 of the bail petition.
6. Considering the aforesaid fact, petitioner is not
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named in the FIR, the name of the petitioner has been transpired
during investigation on the basis of the confessional statement
of co-accused person and prosecution has filed the final form in
favour of the named accused persons, let the petitioner, above
named, be released on bail on furnishing bail bond of
Rs.10,000/- (Ten Thousand) with two sureties of the like amount
each to the satisfaction of learned A.C.J.M., Sherghati, Gaya in
connection with Sherghati (Dobhi) P.S. Case No.568/2023, with
the following conditions:-
(I) Petitioner shall co-operate in the trial and shall be
properly represented on each and every date fixed by the Court
and shall remain physically present as directed by the Court and
on his/her absence on two consecutive dates without sufficient
reason, his/her bail bond shall be cancelled by the Court below.
(II) If the petitioner tampers with the evidence or the
witnesses, in that case, the prosecution will be at liberty to move
for cancellation of bail.
(III) And, further condition that the court below shall
verify the criminal antecedent of the petitioner and in case at
any stage, it is found that the petitioner has concealed his
criminal antecedent, the court below shall take step for
cancellation of bail bond of the petitioner. However, the
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acceptance of bail bonds in terms of the above-mentioned order
shall not be delayed for purpose of or in the name of
verification.
(Rajesh Kumar Verma, J)
Nitesh/-
U T
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