Patna High Court
Sangeeta Kumari @ Sangita KumariversusThe State of Bihar
- Decided
- Disposal
- DISMISSED
- Bench
- SANDEEP KUMAR
Holding
The Court dismissed the bail application, refusing to grant regular bail and declining to review its earlier order.
Summary
The petitioner, Sangeeta Kumari, applied for regular bail in a case registered under sections 140(3), 103, 61(2) and 238 of the B.N.S. The trial court had earlier rejected her bail application on 9 April 2025, noting the seriousness of the offence and the recovery of the deceased's body and other articles. The petitioner argued that she has a clean antecedent, has been in custody since 15 September 2024, and that charges have not yet been framed. The High Court examined whether the earlier order could be reviewed and whether the absence of framed charges warranted bail. Finding no sufficient ground to revisit its prior decision, the Court dismissed the bail application and directed the lower court to expedite the trial and frame charges promptly.
Issues considered
- Whether the petitioner is entitled to regular bail at this stage of the proceedings
- Whether the earlier bail denial can be reviewed in light of the petitioner's clean antecedent and the fact that charges have not been framed
Legislation cited
- B.N.S. — s. 103, 140(3), 238, 61(2)
Subjects
- regular bail
- bail application
- charge framing
- criminal procedure
- B.N.S. sections 140(3) 103 61(2) 238
- trial expedite
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.9823 of 2026
Arising Out of PS. Case No.-591 Year-2024 Thana- MOHANIYA District- Kaimur (Bhabua)
======================================================
Sangeeta Kumari @ Sangita Kumari Wife of Santosh Kumar God @ Gond
Resident of Village- Baraintha, P.O.- Bamhaur Khas, Bhagirathpur, P.S.-
Mohaniya, District- Kaimur (Bhabua)
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr.Kumar Vikram, Advocate
For the Opposite Party/s : Mr.Arun Kumar Singh, APP
======================================================
CORAM: HONOURABLE MR. JUSTICE SANDEEP KUMAR
ORAL ORDER
2 16-02-2026 Heard the parties.
2. This is the second attempt of the petitioner for
grant of regular bail in connection with Mohaniya P.S. Case No.
591 of 2024 registered for the offence under Sections 140(3),
103, 61(2) and 238 of the B.N.S. Earlier the bail application of
the petitioner was rejected vide order dated 09.04.2025 passed
in Cr. Misc. No. 2479 of 2025 which reads as under:-
Heard learned counsel for the petitioner,
learned APP for the State and learned counsel for the
informant.
2 . This application for grant of regular bail
arises out of Mohaniya P.S. Case No.591 of 2024
registered for the offence punishable under section
140(3), 103, 612(2) and 238 of the B.N.S. 2023.
3 . On the confession of the petitioner, the
dead- body of the deceased and other articles have been
recovered by the Police. The petitioner is alleged to have
involved in the crime. He is in custody since 15.09.2024.
4 . Considering the aforesaid facts, I
Patna High Court CR. MISC. No.9823 of 2026(2) dt.16-02-2026
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am not inclined to grant the petitioner privilege
of regular bail. Accordingly, this bail application is
rejected.
3. It has been submitted by the learned counsel for the
petitioner that petitioner has clean antecedent and he is custody
since 15.09.2024. Learned counsel further submits that till now
charges have not been framed.
4. Considering the aforesaid facts, this Court finds no
ground to review its earlier order.
5. Accordingly, this application is dismissed again
with direction to the concerned court below to expedite the trial
and frame the charges at the earliest.
(Sandeep Kumar, J)
tusharika/-
U T
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