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Patna High Court

Sanni Singh @ Sanni Kumar SinghversusThe State of Bihar

Decided
Disposal
BAIL GRANTED

Holding

The court granted anticipatory bail to the petitioner subject to the conditions prescribed under Section 482(2).

Summary

The petitioner, Sanni Singh, applied for anticipatory bail fearing arrest in a case registered under multiple sections of the Bihar Negotiable Statutes (BNS) 2023, including offences of assault and robbery. He alleged that the informant’s complaint was false, arising from a wage dispute, and denied any assault, claiming the alleged injuries were minor. The State opposed the bail, contending the seriousness of the offences. The court considered the petitioner’s antecedent, the delay of 24 days before the FIR was examined by the trial court, and the possibility of false implication. Relying on Section 482(2) of the Bihar Negotiable Statutes (BNSS), the court ordered that the petitioner be released on anticipatory bail upon furnishing a bail bond of Rs.10,000 with two sureties, subject to conditions. The anticipatory bail application was therefore allowed.

Issues considered

  • Whether anticipatory bail should be granted to the petitioner under Section 482(2) in view of the allegations under Sections 126(2), 115(2), 74, 303(2), 352, 351(2), 109(1) and 3(5) of the BNS, 2023.
  • Whether the delay in the trial court’s examination of the FIR and the claim of false implication affect the grant of bail.

Subjects

  • anticipatory bail
  • false implication
  • assault
  • Section 482
  • bail bond
  • criminal procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.9458 of 2026
                        Arising Out of PS. Case No.-179 Year-2025 Thana- Geedha District- Bhojpur
                 ======================================================
                 Sanni Singh @ Sanni Kumar Singh S/O Ramesh Kr. Singh Resident of
                 Village- Matiyara Police Station- Gidha, Dist.- Bhojpur

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :        Mr. Ashok Kumar Singh, Advocate
                 For the Opposite Party/s :        Mr. Shailendra Kumar, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
                                       ORAL ORDER

2   26-03-2026                  1. Heard learned counsel for the petitioner and

                   learned A.P.P. for the State.

                                2. The petitioner apprehends his arrest in a case

                   registered for the offences punishable under Sections 126(2),

                   115(2), 74, 303(2), 352, 351(2), 109(1) and 3(5) of the BNS,

                   2023.

                                3. Learned counsel for the petitioner submits that

                   petitioner has antecedent of one case and the informant alleges

                   that petitioner and his father (Ramesh) used to force her for

                   doing      household       work,      further     petitioner      touched        her

                   inappropriately, on objection petitioner assaulted her by brick

                   causing injury on head, thereafter Ramesh assaulted by brick

                   causing injury on hand and petitioner snatched her locket worth

                   Rs. 20,000/-.
Patna High Court CR. MISC. No.9458 of 2026(2) dt.26-03-2026
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                       4. Learned counsel for the petitioner submits that

          petitioner has been falsely implicated in the instant case by the

          informant, it is next submitted that since a dispute had arisen on

          account of payment of wage, as such, a false came came to be

          instituted with exaggerated allegation. It is further submitted

          that though allegation is of assaulting by bricks, but then the

          petitioner vehemently denies the said allegation that he ever

          assaulted the informant. It is also submitted that even presuming

          what has been is true without admitting, then the injury has

          been opined to be simple in nature. It is also submitted that the

          FIR was instituted on 24.09.2025 and the same was seen by the

          learned Trial Court on 18.10.2025 i.e. after a delay of 24 days,

          which also casts as aspersion on the case of the prosecution.

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

          anticipatory bail application of the petitioner.

                       6. Considering the submissions made by the learned

          counsel for the petitioner, the petitioner above-named, in the

          event of his arrest or surrender within a period of six weeks

          from today, be released on anticipatory bail on furnishing bail

          bonds of Rs. 10,000/- (Rupees Ten Thousand) with two sureties

          of the like amount each to the satisfaction of the learned trial

          court where the case is pending/successor court in connection
            Patna High Court CR. MISC. No.9458 of 2026(2) dt.26-03-2026
                                                        3/3




                      with Gidha P.S. Case No. 179 of 2025 subject to the conditions

                      as laid down under Section 482 (2) of BNSS.

                                   7. Accordingly,         the    instant   anticipatory   bail

                      application is allowed.



                                                              (Satyavrat Verma, J)
Rishabh/-

U      T


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