Patna High Court

Balam Manjhi @ BalamversusThe State of Bihar

Decided: 30 January 2026
Disposal: BAIL GRANTED
Bench: R P MISHRA

Holding

Anticipatory bail is granted to the petitioner subject to the conditions prescribed under Section 482(2) of the Bharatiya Nagarika Suraksha Sanhita, 2023.

Summary

The petitioner, Balam Manjhi, was implicated in a case (Wazirganj P.S. Case No. 570 of 2022) involving offences under Sections 147, 148, 149, 323, 337, 307, 504 and 506 of the Indian Penal Code. He claimed innocence, arguing that the allegations against him were vague, omnibus and that he had no criminal antecedent. The State opposed his bail, contending the seriousness of the offences. The High Court examined whether the petitioner was entitled to anticipatory bail under Section 482(2) of the Bharatiya Nagarika Suraksha Sanhita, 2023, considering the nature of the accusations and the petitioner’s cooperation. The Court ordered that, if arrested or surrendered within six weeks, the petitioner be released on anticipatory bail upon furnishing a bail bond of Rs.15,000 with two sureties, subject to the conditions of Section 482(2).

Issues considered

Whether the petitioner is entitled to anticipatory bail under Section 482(2) of the Bharatiya Nagarika Suraksha Sanhita, 2023 despite allegations under multiple IPC sections.
Whether the allegations against the petitioner are sufficiently specific to deny bail.
Whether the petitioner poses a risk of fleeing, tampering with evidence or influencing witnesses.

Legislation cited

Bharatiya Nagarika Suraksha Sanhita, 2023 — s. 482
Indian Penal Code — s. 147, 148, 149, 307, 323, 337, 504, 506

Subjects

anticipatory bail
Section 482
Bharatiya Nagarika Suraksha Sanhita
Indian Penal Code
high court
criminal procedure
bail conditions
non-violent offences

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.90992 of 2025
                       Arising Out of PS. Case No.-570 Year-2022 Thana- WAJIRGANJ District- Gaya
                 ======================================================
                 Balam Manjhi @ Balam S/O Munarik Manjhi @ Mundrika Manjhi R/O Vill.-
                 Shankar Bigha,P.S- Wazirganj, Dist- Gaya ji
                                                                      ... ... Petitioner/s
                                                   Versus
                 The State of Bihar
                                                               ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Mr.Arvind Kumar Singh, Advocate
                 For the Opposite Party/s :       Mr.Mritunjay Kumar Nirala, A.P.P.
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE RUDRA PRAKASH
                 MISHRA
                                       ORAL ORDER

2   30-01-2026                  Heard learned counsel for the petitioner and learned

                   APP for the State.

                                2. The petitioner apprehends arrest in connection with

                   Wazirganj P.S. Case No. 570 of 2022, punishable for the

                   offences registered under Sections 147, 148, 149, 323, 337, 307,

                   504 and 506 of the Indian Penal Code.

                                3. The prosecution case, in short, is that, the petitioner

                   along with other co-accused persons assaulted the informant and

                   his family members by means of iron rod, lathi, bhala and tangi

                   due to which they sustained injuries.

                                4. Learned counsel for the petitioner submits that the

                   petitioner is innocent and has falsely been implicated in the

                   present case. Learned counsel for the petitioner further submits

                   that no specific allegation has been attributed against the

                   petitioner. The allegation levelled against the petitioner is

                   general and omnibus in nature. It is further submitted that there
           Patna High Court CR. MISC. No.90992 of 2025(2) dt.30-01-2026
                                                       2/2




                     is case and counter case between the parties. The injuries

                     received by the injured are simple in nature. The petitioner has

                     got no criminal antecedent. Learned counsel for the petitioner

                     further submits that other co-accused has been granted bail by

                     this Court vide order dated 20.12.2024 passed in Cr. Misc. No.

                     33281 of 2024.

                                  5. Learned APP for the State has vehemently opposed

                     the prayer for grant of bail to the petitioners.

                                  6. Considering the aforesaid facts and circumstances

                     of the case, let the petitioner above named, in the event of

                     arrest/surrender before the learned Court below within a period

                     of six weeks from today, be released on anticipatory bail on

                     furnishing bail bonds of Rs. 15,000/- (Rupees Fifteen Thousand)

                     with two sureties of the like amount each to the satisfaction of

                     Court below/concerned Court in connection with Wazirganj P.S.

                     Case No. 570 of 2022, subject to the conditions as laid down

                     under Section 482(2) of the Bharatiya Nagarika Suraksha

                     Sanhita, 2023.


                                           (Rudra Prakash Mishra, J)
manish/-
U      T

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