Patna High Court
Md. Rehan RajaversusThe State of Bihar
- Decided
- Disposal
- DISMISSED
- Bench
- SANDEEP KUMAR
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
- Bharatiya Nyaya Sanhita, 2023 — s. 143(6)
- Juvenile Justice (JJ) Act — s. 79
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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