Patna High Court

Pankaj Singh @ Pankaj Kumar SinghversusThe State of Bihar

Decided: 19 March 2026
Disposal: BAIL REJECTED
Bench: ALOK KUMAR SINHA

Holding

The court held that, in view of the accused's confessional statement and corroborating witness testimony, bail could not be granted.

Summary

Pankaj Singh was charged with murder under Section 103(i) of the Bharatiya Nyaya Sanhita Act, 2023 for allegedly killing Hareram Singh with an axe. The petitioner claimed innocence, asserting lack of eyewitnesses and incriminating material, and sought regular bail. The prosecution presented a confessional statement by the accused and statements of three witnesses supporting the charge. The court examined the case diary and found the allegation direct, specific, and corroborated by the confession and witness testimony. Consequently, the court concluded that the petitioner was not entitled to the privilege of bail and rejected the bail application.

Issues considered

Whether the petitioner is entitled to regular bail in a murder case under Section 103(i) of the Bharatiya Nyaya Sanhita Act, 2023

Subjects

bail
murder
confession
witness testimony
criminal procedure
Bharatiya Nyaya Sanhita

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.9037 of 2026
                        Arising Out of PS. Case No.-223 Year-2025 Thana- SUPAUL District- Supaul
                 ======================================================
                 Pankaj Singh @ Pankaj Kumar Singh Son of Ramchandra Singh R/o
                 Brahmpur, Ward No. 05, P.S. and Distt. - Supaul.

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :        Mr. Navneet Kumar, Adv
                 For the Opposite Party/s :        Mr. Anand Kishore Choudhary, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ALOK KUMAR SINHA
                                       ORAL ORDER

3   19-03-2026                     Heard learned counsel for the petitioner and learned

                   Additional Public Prosecutor for the State.

                                2. The petitioner seeks bail in connection with Supaul

                   P.S. Case No. 223 of 2025 registered for the offence punishable

                   under Sections 103 (i) of Bharatiya Nyaya Sanhita Act, 2023.

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

                   05.05.2025 at about 07:00 P.M., the informant received

                   information from the villagers that Hareram Singh was returning

                   from market and when he reached near Brahmpur small bridge,

                   accused Pankaj Singh, son of Ramchandra Singh, assaulted him

                   by axe, thereby he died. After receiving that information, he

                   informed the SHO and reached at the place of occurrence and
Patna High Court CR. MISC. No.9037 of 2026(3) dt.19-03-2026
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          there were several persons present and the dead body of the

          deceased was lying on the road. On the basis of this

          information, the police of PS Sadar Supaul registered the FIR

          against the accused Pankaj Singh.

                       4. Learned counsel for the petitioner submits that the

          petitioner is innocent and has falsely been implicated in this

          case. He further submits that there is neither any eye witness of

          the incident nor any incriminating materials have been

          recovered from the petitioner. The petitioner has no criminal

          antecedent and is in custody since 07.05.2025.

                       5. Learned APP appearing for the State opposes the

          prayer for regular bail of the petitioner.

                       6. Considering the fact that the police has recorded the

          confessional statement of the petitioner-accused and also in the

          case diary, recorded the statement of the witnesses, namely,

          Sanjay Kumar Singh, Narayan Singh and Jai Jai Ram and all

          witnesses have supported the prosecution case. Further, as per

          the confessional statement of the petitioner-accused, the

          deceased was his neighbour and on account of dispute between

          them, the petitioner is alleged to have caused the death of the

          deceased by axe and on scrutiny of the case diary, it transpires

          that the allegation against petitioner is direct and specific, this
          Patna High Court CR. MISC. No.9037 of 2026(3) dt.19-03-2026
                                                      3/3




                    Court is not inclined to grant privilege of bail to the petitioner.

                                 7. Accordingly, the present bail application stands

                    rejected.



                                             (Alok Kumar Sinha, J)
kiran/-

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