Patna High Court

Satyendra YadavversusThe State of Bihar

Decided: 12 March 2026
Disposal: BAIL GRANTED
Bench: ANIL KUMAR SINHA

Holding

The court granted anticipatory bail to the petitioner.

Summary

The petitioner, Satyendra Yadav, applied for anticipatory bail in a case arising from a neighbourhood quarrel that escalated into a physical altercation on 28 July 2025. The FIR alleged offences under several sections of the Bharatiya Nyaya Sanhita, 2023, including assault with a lathi‑danda, use of an iron rod, and causing injuries. The petitioner argued that the incident was a minor dispute between children, the injuries were not serious, and he had no prior criminal record. The court considered the nature of the allegations, the minor extent of the injury, and the petitioner’s clean antecedent. Finding no compelling reason to deny bail, the judge granted anticipatory bail subject to a bail bond and conditions under Section 482(2) of the Bharatiya Nagarik Suraksha Sanhita.

Issues considered

Whether anticipatory bail should be granted in a case involving alleged offences under the Bharatiya Nyaya Sanhita, 2023.
Whether the minor nature of the injury and lack of criminal antecedent justify the grant of anticipatory bail.
Whether conditions under Section 482(2) of the Bharatiya Nagarik Suraksha Sanhita are applicable.

Legislation cited

Bharatiya Nagarik Suraksha Sanhita — s. 482(2)
Bharatiya Nyaya Sanhita, 2023 — s. 109, 115(2), 117(2), 127(1), 3(5), 351(1), 352

Subjects

anticipatory bail
assault
minor injury
neighbour dispute
Bharatiya Nyaya Sanhita
Bharatiya Nagarik Suraksha Sanhita
Section 482
bail conditions

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.9394 of 2026
                       Arising Out of PS. Case No.-225 Year-2025 Thana- CHAKAND District- Gaya
                 ======================================================
                 Satyendra Yadav S/O Late Ramchandra Yadav R/O Village- Mishree Bigha,
                 P.S- Chakand, Distt.- Gaya.

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

                                                                            ... ... Opposite Party/s

                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr. Vinod Kumar, Advocate
                 For the Opposite Party/s :      Ms. Shaheen Begum, A.P.P.
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ANIL KUMAR SINHA
                                       ORAL ORDER

2   12-03-2026                   Heard learned Counsel for the petitioner and learned

                   Additional Public Prosecutor for the State.

                                2. This application, for grant of anticipatory bail,

                   arises out of Chakand Police Station Case No. 225 of 2025,

                   disclosing offences under Sections 127(1), 115(2), 117(2), 109,

                   352, 351(1) and 3(5) of Bharatiya Nyaya Sanhita, 2023.

                                3. The prosecution case, as per the First Information

                   Report, is that on 28.07.2025, in the morning, the son of the

                   informant was playing outside his house. In the meanwhile, the

                   informant heard that the children playing outside were abusing

                   each other. When the informant came out of his house, he saw

                   that there was free fight between his son and the son of the

                   petitioner. The informant tried to intervene, but the petitioner
Patna High Court CR. MISC. No.9394 of 2026(2) dt.12-03-2026
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          along with other accused persons assaulted him and his son with

          lathi-danda. It has further been alleged that the petitioner

          assaulted the informant with iron rod, causing head injury. The

          co-accused, Pawan Kumar, assaulted the informant’s son on his

          nose, causing injury.

                        4. Learned counsel for the petitioner submits that

          both the parties are neighbours and the occurrence has taken

          place due to quarrel between the children. The injury sustained

          by the informant, which has been discussed in the impugned

          order, appears to be minor in nature. Petitioner is having no

          criminal antecedent.

                       5. Regards being had to the submissions made by the

          parties and taking into consideration the nature of allegation and

          the fact that the injury does not appear to be serious in nature, I

          am inclined to grant the petitioner privilege of anticipatory bail.

                       6. This application is, accordingly, allowed.

                       7. Let the petitioner, above named, in the event of his

          arrest or surrender before the Court below within four weeks, be

          released on bail 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, Gaya, in

          connection with Chakand Police Station Case No. 225 of 2025,
           Patna High Court CR. MISC. No.9394 of 2026(2) dt.12-03-2026
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                     subject to the condition laid down under Section 482 (2) of the

                     Bharatiya Nagarik Suraksha Sanhita.



                                              (Anil Kumar Sinha, J)
Siwani/-

U      T

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