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Patna High Court

Md. Rehan RajaversusThe State of Bihar

Decided
Disposal
DISMISSED

Holding

The High Court denied regular bail to the petitioner, holding that the seriousness of the human‑trafficking charges and the Supreme Court’s direction preclude bail.

Summary

The petitioner, Md. Rehan Raja, was arrested on 18 January 2025 for allegedly trafficking children to Punjab and Haryana. He is charged under Section 143(6) of the Bharatiya Nyaya Sanhita, 2023, Section 79 of the Juvenile Justice Act, and Section 3/14 of the Child Adolescent Labour (Prohibition and Regulation) Act, 1986. The petitioner applied for regular bail, claiming a clean antecedent, but the High Court rejected the bail application, citing the seriousness of the human‑trafficking offence. The Court relied on the Supreme Court’s direction in Pinki v. State of Uttar Pradesh (2025) to expedite the trial and ordered the trial to be concluded within six months. Consequently, the bail petition was dismissed and the trial was directed to proceed swiftly.

Issues considered

  • Whether regular bail can be granted to an accused in a human‑trafficking case involving child victims.
  • Whether the Supreme Court’s direction in Pinki v. State of Uttar Pradesh mandates denial of bail and expedited trial.

Legislation cited

Subjects

  • bail
  • human trafficking
  • child trafficking
  • expedited trial
  • Supreme Court direction
  • criminal procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.9908 of 2026
                   Arising Out of PS. Case No.-10 Year-2025 Thana- MUZAFFARPUR RAIL P.S. District-
                                                          Saran
                 ======================================================
                 Md. Rehan Raja S/o Jainuddin Resident of Village - Natua Para, P.S.-
                 Bahadurganj, District- Kishanganj

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

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :      Mr.Sunil Kumar Pandey, Advocate
                 For the Opposite Party/s :      Mr.Brajendra Nath Pandey, 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 Rail P.S. Muzaffarpur

                   Case No. 10 of 2025 registered for the offence under Sections

                   143(6) of B.N.S and Section 79 of J.J. Act and Section 3/14 of

                   Child Adolescent Labour (Prohibition and Regulation) Act,

                   1986. Earlier the bail application of the petitioner was rejected

                   vide order dated 09.07.2025 passed in Cr. Misc. No. 41219 of

                   2025 which reads as under:-

                                               Heard the learned counsel for the petitioner
                                   and learned APP for the State.
                                                2 . The petitioner seeks regular bail in
                                   connection with Muzaffarpur Rail P.S. Case No. 10 of
                                   2025 registered for the offence under Sections 143(6) of
                                   the Bharatiya Nyaya Sanhita, 2023, under Section 79 of
                                   the JJ Act and ¾ of the C.A.L.(P & R) Act.
                                               3 . This is a case of human trafficking. The
              Patna High Court CR. MISC. No.9908 of 2026(2) dt.16-02-2026
                                                          2/2




                                        petitioner was found involved in trafficking children
                                        to Punjab and Haryana. He has been arrested along
                                        with the children. The petitioner is in custody since
                                        18.01.2025.
                                                       4 . Considering the aforesaid facts and
                                        circumstances, I am not inclined to grant bail to the
                                        petitioner. Accordingly, this application for regular bail is
                                        hereby rejected.
                                                    5 . Since this is a case of human trafficking,
                                        the Court below is directed to conclude the trial of the
                                        petitioner and other co-accused within six months from
                                        today as there is a direction of the Hon’ble Supreme
                                        Court regarding the same in the case of Pinki Vs. State of
                                        Uttar Pradesh reported as 2025 SCC OnLine SC 781.
                                                     6 . Let a copy of this order be communicated
                                        to the Principal District and Sessions Judge, Saran at
                                        Chapra through FAX for its compliance forthwith.

                                     3. It has been submitted by the learned counsel for the

                        petitioner that petitioner has got clean antecedent and he is

                        custody since 18.01.2025.

                                     4. This application is dismissed again in view of the

                        judgment of the Hon’ble Supreme Court in the case of Pinki vs.

                        State of U.P. & Anr. reported as 2025 INSC 482 = 2025 SCC

                        OnLine SC 781.

                                     5. The Court below is directed to expedite the trial

                        and conclude the same at the earliest.



                                                   (Sandeep Kumar, J)
tusharika/-

U       T


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