Patna High Court

Satish Kumar ChoudharyversusThe State of Bihar

Decided: 15 January 2026
Disposal: BAIL REJECTED
Bench: ALOK KUMAR SINHA

Holding

The Court refused to grant anticipatory bail, holding that the seriousness of the alleged offences precludes the privilege of anticipatory bail.

Summary

Satish Kumar Choudhary sought anticipatory bail after being implicated in a cyber‑fraud case (Rohtas Cyber PS Case No. 49 of 2025) involving alleged violations of Sections 318(4), 303(2), 319(2) of the BNS, 2023 and Sections 66(C) and 66(D) of the IT Act, 2008. The prosecution alleged that the petitioner, after seeing a YouTube advertisement for the SPRINT999 app, sent a large sum of money and later received threatening messages when the promised returns stopped. The petitioner contended he has a clean record, was falsely implicated, and had no role in the transactions, merely being the owner of a mobile phone used for alleged threats. The State opposed the grant of anticipatory bail, emphasizing the seriousness of the offences. The Court, after reviewing the FIR and submissions, declined to grant anticipatory bail, finding the allegations serious and the petition unmeritorious.

Issues considered

Whether anticipatory bail should be granted to the petitioner in view of the alleged cyber‑fraud offences.
Whether the nature of the allegations under the BNS, 2023 and the IT Act, 2008 warrants denial of anticipatory bail.
Whether the petitioner’s alleged involvement can be established sufficiently to justify bail.

Legislation cited

Bihar Narcotic Substances (BNS) Act — s. 303(2), 318(4), 319(2)
Information Technology Act, 2008 — s. 66(C), 66(D)

Subjects

anticipatory bail
cyber fraud
IT Act
Section 66C
Section 66D
bail jurisprudence
false implication
criminal procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.91959 of 2025
                        Arising Out of PS. Case No.-49 Year-2025 Thana- Cyber P.S. District- Rohtas
                 ======================================================
                 Satish Kumar Choudhary S/O Janardan Chodhary R/O Village- Dhanpurwa,
                 P.S- Ara Nagar, Distt.- Bhojpur.
                                                                        ... ... Petitioner/s
                                                  Versus
                 The State of Bihar
                                                                 ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :         Mr. Bhaskar Shankar, Advocate
                 For the Opposite Party/s :         Mr. Harendra Prasad, A.P.P.
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ALOK KUMAR SINHA
                                       ORAL ORDER

2   15-01-2026                     Heard learned counsel for the petitioner and learned

                   A.P.P. for the State.

                                2. The petitioner apprehends his arrest in connection

                   with Rohtas (Cyber) P.S. Case No. 49 of 2025, registered for the

                   offences punishable under Sections 318(4), 303(2), 319(2) of

                   the BNS, 2023 and Sections 66(C), 66(D) of IT Act, 2008.

                                3. The case of the prosecution, in short, as per the

                   informant that he learnt from a Youtube ad Video that

                   SPRINT999 is an application where money can be earned by

                   playing games. It is further alleged that he sent a message “Hii”

                   on WhatsApp from the number received from that game where

                   he got a link where the informant sent Rs.40,11,744.96/- from

                   his account number and from seventeen account numbers of his

                   friend. It is further alleged that the informant received

                   2,00,000/- in his account at the very outset but after a certain

                   point of time the returns stopped coming in his account and the

                   informant tried to contact on that mobile number but he did not
          Patna High Court CR. MISC. No.91959 of 2025(2) dt.15-01-2026
                                                      2/2




                    get response and he suspected a cyber fraud. It is also alleged

                    that the informant received threatening messages thereafter.

                                 4. Learned counsel for the petitioner submits that the

                    petitioner is a person with clean antecedent. The entire

                    prosecution story is false, fabricated and concocted. Learned

                    counsel for the petitioner submits that from perusal of FIR it is

                    apparent that petitioner has no role in the transaction of any

                    money. It is next submitted that the petitioner has been falsely

                    implicated as he is said to be owner of mobile phone which is

                    used for threatening the informant to manage the case.

                                 5. Learned A.P.P. for the State opposes the prayer of

                    anticipatory bail.

                                 6. From the perusal of the allegations levelled in the

                    FIR it is manifest that the petitioner has been alleged to have

                    committed serious offence, and therefore, this Court is not

                    inclined to grant privilege of anticipatory bail to the petitioner.




                                             (Alok Kumar Sinha, J)
Gaurav Sinha/-

U

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