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Santosh Kumar Sahni Vs The State of Bihar — Murder and Culpable Homicide | Patna HC (2025)

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Patna HC
2025
Santosh Kumar Sahni Vs The State of BiharSantosh Kumar Sahni v. The State of Bihar

Allowed¶¶20

Santosh Kumar Sahni v. The State of Bihar

Patna HC3 Sept 2025CR. MISC./28245/2025

Case brief

AI extract

What is this about?

Bail granted; Patna High Court; CRIMINAL MISCELLANEOUS No.28245 of 2025; decided 03-09-2025; Justice Khatim Reza; petitioner Santosh Kumar Sahni v. The State of Bihar; advocates Raj Krishna Jha (petitioner) and Rina Sinha, APP (State); Bahadurpur P.S. Case No. 138 of 2022 dated 16.05.2022; murder of informant's brother; Sections 302/34 IPC; Section 27 Arms Act; conversion to Sections 406, 420, 379, 302, 120(B), 201 IPC; unnamed in FIR; implication via confessional statement of co-accused Md. Shabir @ Jahid @ Tanveer @ Sabbu; petitioner not identified through CCTV footage; co-accused granted bail in Criminal Miscellaneous No. 21358 of 2025 on 20.08.2025; custody since 02.02.2025; no criminal antecedents; chargesheet submitted; bail bonds Rs. 10,000/- with two sureties of like amount; Magistrate-1st Class, Patna.

What did the court decide?

Release on bail upon furnishing bail bonds of Rs. 10,000/- (ten thousand) with two sureties of the like amount each, to the satisfaction of the learned Magistrate-1st Class, Patna, in connection with Bahadurpur P.S. Case No. 138 of 2022.

Why is it important?

Bail granted: the petitioner is to be released on bail upon furnishing bail bonds of Rs. 10,000/- (ten thousand) with two sureties of the like amount each, to the satisfaction of the learned Magistrate-1st Class, Patna, in connection with Bahadurpur P.S. Case No. 138 of 2022. ¶¶20

What the court decided

AI extract

Outcome

Release on bail upon furnishing bail bonds of Rs. 10,000/- (ten thousand) with two sureties of the like amount each, to the satisfaction of the learned Magistrate-1st Class, Patna, in connection with Bahadurpur P.S. Case No. 138 of 2022.

Issue for consideration

Whether petitioner Santosh Kumar Sahni, whose name transpired during investigation on the basis of the confessional statement of co-accused Md. Shabir @ Jahid @ Tanveer @ Sabbu, should be released on bail in connection with Bahadurpur P.S. Case No. 138 of 2022.

Court's answer

Bail granted: the petitioner is to be released on bail upon furnishing bail bonds of Rs. 10,000/- (ten thousand) with two sureties of the like amount each, to the satisfaction of the learned Magistrate-1st Class, Patna, in connection with Bahadurpur P.S. Case No. 138 of 2022.

Detailed headnote1 paragraphs

Patna High Court (Khatim Reza, J.), oral order dt. 03-09-2025 in CRIMINAL MISCELLANEOUS No.28245 of 2025 arising out of Bahadurpur P.S. Case No. 138 of 2022 (Patna): bail granted to petitioner Santosh Kumar Sahni. FIR lodged against unknown persons for the murder of the informant's brother under Sections 302/34 IPC and Section 27 Arms Act, later converted to Sections 406, 420, 379, 302, 120(B), 201 IPC and Section 27 Arms Act; petitioner not named in FIR and not identified through CCTV footage, his name having surfaced solely on the confessional statement of co-accused Md. Shabir @ Jahid @ Tanveer @ Sabbu, who had already been granted bail by a Co-ordinate Bench in Criminal Miscellaneous No. 21358 of 2025 (order dt. 20.08.2025). Petitioner in custody since 02.02.2025, no criminal antecedents, chargesheet filed. Released on bail bonds of Rs. 10,000/- with two sureties of the like amount each to the satisfaction of the learned Magistrate-1st Class, Patna.

A

IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.28245 of 2025

Arising Out of PS. Case No.-138 Year-2022 Thana- BAHADURPUR District- Patna

======================================================

Santosh Kumar Sahni S/o- Rajendra Sahni Mohalla- Ghagha Ghat, Police Station- Sultanganj, District- Patna

... ... Petitioner/s

Versus

The State of Bihar

... ... Opposite Party/s

====================================================== Appearance : For the Petitioner/s : Mr. Raj Krishna Jha, Advocate For the Opposite Party/s : Mr. Rina Sinha, APP ======================================================

CORAM: HONOURABLE MR. JUSTICE KHATIM REZA ORAL ORDER

4 03-09-2025

Heard learned counsel for the petitioner and learned

A.P.P. for the State.

The petitioner seeks bail in connection with Bahadurpur P.S. Case No. 138 of 2022 dated 16.05.2022, instituted for the offence punishable under Sections 302/34 of the Indian Penal Code and Section 27 of the Arms Act, which has been converted into Section 406, 420, 379, 302, 120(B), 201 of the I.P.C and Section 27 of the Arms Act on the basis of fardbeyan of the informant dated 16.05.2022.

As per the prosecution case, the brother of the informant was shot dead by some unknown person and the name of the petitioner transpired during investigation for being involved in the said occurrence on the basis of confessional statement of co-accused Md. Shabir @ Jahid @ Tanveer @

Patna High Court CR. MISC. No.28245 of 2025(4) dt.03-09-2025 2/3

Sabbu.

Learned counsel for the petitioner submits that the petitioner is innocent and he has been falsely implicated in this case. It is further submitted that FIR has been lodged against unknown persons. The petitioner is not named in the FIR. The name of the petitioner has been transpired in this case only on the basis of confessional statement of co-accused Md. Shabir @ Jahid @ Tanveer @ Sabbu, who was identified by CCTV footage. The petitioner was not identified through CCTV footage. The aforesaid co-accused, Md. Shabir has been granted bail vide order dated 20.08.2025 passed by a Co-ordinate Bench of this Court in Criminal Miscellaneous No. 21358 of 2025. Lastly, it has been submitted that the petitioner is in custody since 02.02.2025, having no criminal antecedents and chargesheet has been submitted in the case.

Learned A.P.P. has opposed the prayer for bail of the petitioner.

Having considered the facts and circumstances of the case and submissions of learned counsel for the parties, let the petitioner be released on bail upon furnishing bail bonds of Rs. 10,000/- (ten thousand) with two sureties of the like amount each to the satisfaction of the learned Magistrate-1^st Class, Patna

Patna High Court CR. MISC. No.28245 of 2025(4) dt.03-09-2025 3/3

in connection with Bahadurpur P.S. Case No. 138 of 2022.

(Khatim Reza, J)

Sankalp/-

U T

Issues for consideration

1 issue framed by the court

AI extract

1.
Whether petitioner Santosh Kumar Sahni, whose name transpired during investigation on the basis of the confessional statement of co-accused Md. Shabir @ Jahid @ Tanveer @ Sabbu, should be released on bail in connection with Bahadurpur P.S. Case No. 138 of 2022.¶¶14
The court held
Bail granted: the petitioner is to be released on bail upon furnishing bail bonds of Rs. 10,000/- (ten thousand) with two sureties of the like amount each, to the satisfaction of the learned Magistrate-1st Class, Patna, in connection with Bahadurpur P.S. Case No. 138 of 2022.ratio¶¶20

Cases cited

Colour shows how this judgement treated each authority

AI extract

Criminal Miscellaneous No. 21358 of 2025Referred¶¶18

Statutes considered

3 provisions across 2 enactments

AI extract

Indian Penal Code302/34¶¶14 406, 420, 379, 302, 120(B), 201¶¶14
Arms Act27¶¶14

Procedural history

How this case reached the court

AI extract

Prior proceeding
Bahadurpur P.S. Case No. 138 of 2022 dated 16.05.2022, instituted on the fardbeyan of the informant dated 16.05.2022 for offences under Sections 302/34 IPC and Section 27 Arms Act; subsequently converted to Sections 406, 420, 379, 302, 120(B), 201 IPC and Section 27 Arms Act.¶¶14
Prior proceeding
Informant's brother shot dead by unknown person(s); petitioner's name transpired during investigation on the basis of the confessional statement of co-accused Md. Shabir @ Jahid @ Tanveer @ Sabbu.¶¶15
Prior proceeding
Co-accused Md. Shabir granted bail by a Co-ordinate Bench of this Court vide order dated 20.08.2025 in Criminal Miscellaneous No. 21358 of 2025.¶¶18
Prior proceeding
Petitioner in custody since 02.02.2025; stated to have no criminal antecedents; chargesheet submitted in the case.¶¶18

Parties & counsel

AI extract

petitioner
Santosh Kumar Sahni¶¶4
Raj Krishna Jha
respondent
The State of Bihar¶¶7
Rina Sinha

Coram

AI extract

Khatim Rezaauthor¶¶10

Case details

As recorded by the court registry

Court: Patna HC
Decided on: 3 Sept 2025 · September
Registered: 24 Apr 2025
Case no.: CR. MISC./28245/2025
CNR: BRHC010370482025
Topic: Murder and Culpable Homicide
Bench: Khatim Reza
Disposal: BAIL GRANTED
Case type: CRIMINAL MISCELLANEOUS

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Cite this judgement

Santosh Kumar Sahni v. The State of Bihar, CR. MISC./28245/2025 (PAT), decided on 3 September 2025.

The Patna High Court publishes no neutral citation for this judgement — cite it by case number and date of decision.

Cases cited1

Criminal Miscellaneous No. 21358 of 2025Referred¶¶18

Open Authorities

Statutes3

Indian Penal Code302/34 · 406, 420, 379, 302, 120(B), 201
Arms Act27

View all statutes

Procedural history4

Bahadurpur P.S. Case No. 138 of 2022 dated 16.05.2022, instituted on the fardbeyan of the informant dated 16.05.2022 for offences under Sections 302/34 IPC and Section 27 Arms Act; subsequently converted to Sections 406, 420, 379, 302, 120(B), 201 IPC and Section 27 Arms Act.
Informant's brother shot dead by unknown person(s); petitioner's name transpired during investigation on the basis of the confessional statement of co-accused Md. Shabir @ Jahid @ Tanveer @ Sabbu.

View full history

Bench / Coram

Khatim Reza

Parties & counsel