Patna High Court

Sanoj Manjhi @ Sanoj KumarversusThe State of Bihar

Decided: 19 January 2026
Disposal: BAIL GRANTED
Bench: R P MISHRA

Holding

The court inclined to grant bail to the petitioner, subject to bond and conditions.

Summary

The petitioner, Sanoj Manjhi, applied for bail in a case (PS No. 336 of 2025) under Section 30(a) of the Bihar Prohibition and Excise Act for allegedly possessing 30 litres of country-made liquor. The prosecution alleged recovery of the liquor from a bush, while the petitioner claimed innocence, stating no incriminating material was found in his possession and that the allegation arose from village politics. The petitioner had been in custody since 9 December 2025 and possessed six prior criminal antecedents, and the prosecution argued that Section 103 of the BNSS, 2023 had not been complied with. The court, after considering the facts, the period of custody, and the lack of direct evidence, decided to grant bail subject to a bond of Rs.15,000 with two sureties and specific conditions regarding family surety and appearance in court. The bail order was made pending framing of charge, if not already done.

Issues considered

Whether bail should be granted to the accused in a case under Section 30(a) of the Bihar Prohibition and Excise Act considering the custody period, prior criminal antecedents, and non‑compliance with Section 103 of the BNSS, 2023.

Legislation cited

BNSS, 2023 — s. 103

Subjects

bail
prohibition law
excise
criminal procedure
Section 30(a)
Bihar
antecedents
court conditions

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                               CRIMINAL MISCELLANEOUS No.970 of 2026
                        Arising Out of PS. Case No.-336 Year-2025 Thana- AMNAUR District- Saran
                 ======================================================
                 Sanoj Manjhi @ Sanoj Kumar S/O Indra Dev Manjhi R/O Village-
                 Shekhpura, P.S- Amnour, Distt.- Saran.

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :       Ms. Shweta Anand, Adv.
                 For the Opposite Party/s :       Ms. Shaheen Begum, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE RUDRA PRAKASH
                 MISHRA
                                       ORAL ORDER

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

                   APP for the State.

                           2. The petitioner seeks bail in connection with Amnour

                   PS Case No. 336 of 2025 instituted for the offences under

                   Section 30(a) of the Bihar Prohibition and Excise Act.

                           3. The prosecution case, in short, is that 30 liters of

                   country made liquor was recovered from the bush.

                           4. Learned counsel for the petitioner submits that the

                   petitioner is innocent and has falsely been implicated in the

                   present case. No incriminating material has been recovered from

                   the conscious possession of the petitioner. The petitioner has got

                   no concern with the alleged recovery of liquor. Learned counsel

                   for the petitioner submits that the recovery has been made from
Patna High Court CR. MISC. No.970 of 2026(2) dt.19-01-2026
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          an open place which is accessible to one and all and the name of

          the petitioner transpired in this case on the disclosure made by

          the local chowkidar due to dirty village politics. The petitioner

          is in custody since 09.12.2025 and has got six criminal

          antecedents. There is no compliance of Section 103 of the

          BNSS, 2023.

                  5. Learned A.P.P. for the State has vehemently opposed

          the prayer for grant of bail to the petitioner.

                  6. Considering the aforesaid facts and circumstances of

          the case and the period of custody undergone by the petitioner,

          this Court is inclined to grant bail to the petitioner.

                  7. Let the petitioner be released on bail, after framing of

          charge, if not already framed, on furnishing bail bonds of

          Rs.15,000/- (Fifteen thousand) with two sureties of the like

          amount each to the satisfaction of Court below/concerned Court

          in connection with Amnour PS Case No. 336 of 2025, subject to

          the following conditions:

                  (I) One of the bailors shall be own/close member of the

          family of the petitioner.

                  (II) The petitioner shall appear on each and every date

          fixed at the trial. In case of default in such appearance on two

          consecutive dates, the Trial Court will have liberty to cancel the
           Patna High Court CR. MISC. No.970 of 2026(2) dt.19-01-2026
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                     bail bonds of the petitioner.



                                           (Rudra Prakash Mishra, J)
Siddharth Soni/-

U      T

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