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Patna High Court

Satrudhan Sahni @ Shatrudhan SahaniversusThe State of Bihar

Decided
Disposal
ALLOWED

Holding

The court granted regular bail to the petitioner.

Summary

The petitioner, Satrudhan Sahni, applied for regular bail in a case registered under section 309(4) of the B.N.S., alleging that he was not responsible for the alleged theft of cash and ATM cards. The prosecution alleged that the informant was robbed of cash and ATM cards after being taken in a four‑wheeler, leading to withdrawals of Rs. 9,500 and Rs. 70,000 from his bank accounts. The petitioner’s counsel argued that the informant voluntarily handed over the ATM card and that the petitioner had no involvement in disclosing the PIN, and highlighted that the petitioner’s prior cases were of a different nature and he had been in judicial custody since 14‑09‑2025. The State opposed the bail, but the court, after considering the facts, found no compulsion in the PIN disclosure and deemed the petitioner eligible for bail. Consequently, the court ordered his release on bail upon furnishing a bond of Rs.10,000 with two sureties.

Issues considered

  • Whether the petitioner is entitled to regular bail under section 309(4) of the B.N.S. given the alleged theft of cash and ATM cards
  • Whether the alleged forced disclosure of the ATM PIN affects the bail eligibility

Legislation cited

Subjects

  • regular bail
  • section 309(4)
  • B.N.S.
  • ATM fraud
  • theft
  • criminal antecedent
  • bail order

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.91143 of 2025
                    Arising Out of PS. Case No.-496 Year-2025 Thana- MUZAFFARPUR TOWN District-
                                                       Muzaffarpur
                 ======================================================
                 Satrudhan Sahni @ Shatrudhan Sahani S/O Ram Ayodhya Sahni Resident of
                 Village-Raghunathpur,    Police   Station-  Raghunathpur,    District-
                 EastChamparan at Motihari.

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr. Shashank Shekhar, Advocate
                 For the Opposite Party/s :      Mr. Madhura Nand Jha, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ASHOK KUMAR PANDEY
                                       ORAL ORDER

2   19-01-2026                    Heard learned counsel for the petitioner and learned

                   APP for the State.

                                2. The petitioner has prayed for regular bail in a case

                   registered for the offence punishable under section 309(4) of

                   B.N.S.

                                3. The case of the prosecution is that the informant

                   started his journey for Muzaffarpur by Maurya Express at 7:50.

                   After getting down from train, the informant went to bus stand

                   where the driver of one four wheeler was calling out the

                   passenger for Sheohar and the said driver got him sit in the said

                   vehicle. The driver stopped the vehicle near the highway and

                   took his mobile, cash and his two ATM cards. It has been

                   mentioned in the written report that the two persons were
Patna High Court CR. MISC. No.91143 of 2025(2) dt.19-01-2026
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          already in the said vehicle. After getting off from the highway,

          the informant came to Kushahar at his home by hiring an Auto

          then he came to know that Rs. 9500/- was withdrawn from there

          and about Rs. 70,000/- was withdrawn from the account of

          Gramin Bank, Kushahar.

                       4. Learned counsel for the petitioner submits that the

          petitioner is innocent and has committed no offence. Learned

          counsel for the petitioner has submitted that the informant

          himself has handed over his ATM to the petitioner for

          withdrawing the cash. As without the ATM pin, no cash could

          be withdrawn from the ATM and it is not the case of the

          informant that he was forced to disclose the ATM pin. Learned

          counsel for the petitioner has further submitted that though, the

          petitioner is criminal antecedent of four cases but those are not

          of similar nature. Moreover, he is languishing in judicial

          custody since 14.09.2025.

                       5. Learned APP appearing for the State has

          vehemently opposed the prayer of regular bail.

                       6. Admittedly, it is not the case of the informant that

          he has for that he has disclosed the ATM pin or he was forced to

          disclose the ATM pin

                       7. Having heard learned counsel for the parties and
            Patna High Court CR. MISC. No.91143 of 2025(2) dt.19-01-2026
                                                        3/3




                      considering the facts and circumstances of the case, this court is

                      inclined to enlarge the petitioner on bail. The above named

                      petitioner is directed to be released on bail in connection with

                      Muzaffarpur Town P.S. Case No. 496 of 2025 on furnishing bail

                      bond of Rs.10,000/- (ten thousand) with two sureties of the like

                      amount each to the satisfaction of learned Chief Judicial

                      Magistrate, Muzaffarpur.



                                             (Ashok Kumar Pandey, J)
Shubham/-

U     T


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