Patna High Court

Manoj SahniversusThe State of Bihar

Decided: 22 April 2026
Disposal: BAIL REJECTED
Bench: ALOK KUMAR SINHA

Holding

Anticipatory bail was denied to the petitioner.

Summary

Manoj Sahni applied for anticipatory bail after being implicated in a FIR (Case No.55 of 2025) alleging assault with an iron rod, robbery of Rs.10,000, and other offences under the Bihar Negotiable Instruments Act. The prosecution’s case is based on a statement recorded by the informant four days after the alleged incident. The petitioner contended that he is innocent, the allegations are fabricated due to a personal dispute, and there is no medical evidence supporting the claimed injuries. The State opposed the bail, emphasizing the seriousness of the charges and the direct allegation of grievous assault. The Court, noting the gravity of the accusations and the lack of justification for bail, declined to grant anticipatory bail. Consequently, the petition for anticipatory bail was dismissed.

Issues considered

Whether anticipatory bail should be granted to the petitioner in view of the seriousness of the alleged offences under the Bihar Negotiable Instruments Act.

Legislation cited

Bihar Negotiable Instruments Act — s. 109(1), 115(2), 118(1), 126(2), 303(2), 3(5), 351(2), 352

Subjects

anticipatory bail
criminal law
assault
robbery
FIR
false implication
bail denial
serious offence

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.9033 of 2026
                    Arising Out of PS. Case No.-55 Year-2025 Thana- KHUTAUNA District- Madhubani
                 ======================================================
                 Manoj Sahni S/o- Ram Sevak Sahni Village- Kamalpur PS-Khutauna District-
                 Madhubani
                                                                          ... ... Petitioner/s
                                                 Versus
                 The State of Bihar
                                                                   ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr. Ravi Prakash, Adv.
                 For the Opposite Party/s :      Mr. Pranav Kumar, APP
                                                 Mr. Ramchandra Jha Raman, Adv.
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ALOK KUMAR SINHA
                                       ORAL ORDER

3   22-04-2026                    Heard learned counsel for the petitioner and learned

                   APP for the State.

                                2. The petitioner apprehends his arrest in connection

                   with Khutauna P.S. Case No.55 of 2025 registered for the

                   offence under Sections 126(2), 115(2), 118(1), 109(1), 303(2),

                   352, 351(2), 3(5) of the BNS.

                                3. According to the prosecution, the informant, Rajdev

                   Sahni, gave his statement (fardbeyan) on 25.04.2025 at

                   approximately 12:45 PM. He stated that he is a fish seller and

                   that on 21.04.2025, around 06:00 PM, while returning home on

                   his motorcycle, he was intercepted and abused by several

                   villagers named in the FIR. When he objected, Pramod assaulted

                   him with a lathi, Manoj with an iron rod, and other co-accused

                   with fists and slaps. After he fell, Paro Devi struck him with a
Patna High Court CR. MISC. No.9033 of 2026(3) dt.22-04-2026
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          piece of brick, causing a bleeding injury to his left eye. The

          petitioner, Pramod Sahni, allegedly snatched ₹10,000 before the

          accused fled, threatening to kill him. Accordingly, the FIR was

          registered.

                       4. Learned counsel for the petitioner submits that the

          petitioner is innocent, has committed no offence, and has been

          falsely implicated in the present case. It is further submitted that

          no occurrence took place in the manner alleged; the entire

          prosecution version is a concoction and fabrication. Notably,

          while the alleged incident occurred on 21.04.2025, the

          fardbeyan was recorded only on 25.04.2025, and the F.I.R. was

          subsequently lodged on 29.04.2025. Learned counsel for the

          petitioner next submits that the allegations of assault are not

          corroborated by the medical injury report and the informant

          filed this false case due to a monetary dispute. Furthermore,

          Nathuniya Devi is the petitioner’s mother, and a dispute exists

          because the informant forcibly entered into a second marriage

          with another person. Lastly, it is submitted that no case is made

          out against the petitioner under Sections 126(2), 115(2), 118(1),

          109(1), 303(2), 352, 351(2), and 3(5) of the B.N.S.

                       5. The learned APP opposes the anticipatory bail

          application.
          Patna High Court CR. MISC. No.9033 of 2026(3) dt.22-04-2026
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                                  6. There is direct allegation against the petitioner of

                    having assaulted with iron rod which has led to grievous injury.

                                  7. Considering the seriousness of the allegation, this

                    Court is not inclined to grant privilege of anticipatory bail to the

                    petitioner.

                                  8. Accordingly, the application for anticipatory bail is

                    rejected.


                                             (Alok Kumar Sinha, J)

Prakash Narayan
U      T

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