Disposed¶24

Sanjayananda @ Sanjay Behera@ Lucky v. State of Odisha

Criminal – Pre-arrest bail (ABLAPL)

Orissa HC27 Jul 2026ABLAPL/5041/2026

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Case brief

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What is this about?

High Court of Orissa, Cuttack; ABLAPL No. 5041 of 2026; decided 27.07.2026 by V. Narasingh, J.; pre-arrest (anticipatory) bail declined in POCSO case (Sections 75/76 BNS, Section 12 POCSO Act) arising from Angul P.S. Case No.91 of 2026; charge sheet filed 31.03.2026; four prior criminal cases against petitioner weighed; Section 183 BNSS statement of victim considered; liberty reserved to surrender and seek regular bail on merits; application disposed of.

What did the court decide?

Having perused the Section 183 BNSS statement of the victim, and considering the tenor thereof together with the Petitioner's criminal antecedents, the Court was not inclined to entertain the application for pre-arrest bail. ¶23

Sanjayananda @ Sanjay Behera@ Lucky Vs State of… — Child Sexual Offences (POCSO) | Orissa HC (2026)

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IN THE HIGH COURT OF ORISSA AT CUTTACK

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ABLAPL No. 5041 of 2026

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Sanjayananda @ Petitioner Sanjay Behera@ Lucky^….

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Mr. P.K. Pradhan, Advocate

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-versus-

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State of Odisha

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…. Opposite Parties

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Mr. C.R. Swain, AGA

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CORAM: JUSTICE V. NARASINGH ORDER

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27.07.2026

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Order No.

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03. 1. Heard learned counsel for the Petitioner and learned counsel for the State.

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The Petitioner is seeking pre-arrest bail in connection with Special POCSO Case No.12 of 2026 pending on the file of learned Additional District and Sessions Judge-cum-Special Court under POSCO Act, arising out of Angul P.S. Case No.91 of 2026 for commission of offences punishable under Sections 75/76 of BNS with Section 12 of POCSO Act (Amended), 2012, 2019.

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It is submitted by the learned counsel for the Petitioner that it’s a case of false implication and on instruction, it is further submitted that earlier also similar allegations were made.

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Page 1 of 2

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Learned counsel for the State opposes the prayer for pre-arrest bail and submits that charge sheet has been filed on 31.03.2026 and the Petitioner

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has the following criminal antecedents;

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i. Angul P.S. Case No.138 of 2025 U/s.126(2)/115(2)/296 BNS

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ii. Angul P.S. Case No.726 of 2024 U/s.296/351(2)/3(5) of BNS

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iii. Angul P.S. Case1133 of 2020 U/s.341/294/323/354-B/506 IPC

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iv. Angul P.S. Case No.807 of 2020 U/s.341/294/323/354-B IPC

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Be that as it may, this Court perused the 183 BNSS statement of the victim.

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Considering tenor thereof and the criminal antecedent of Petitioner, this Court is not inclined to entertain the application for pre-arrest bail. However, in the event the Petitioner surrenders before the learned Court in seisin in the aforesaid case and moves an application for his release on bail, the same shall be considered on its own merit.

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