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Manish Kumar Vs The State of Bihar — Patna HC (2025) — LawSathi Research

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Patna HC
2025
Manish Kumar Vs The State of BiharManish Kumar v. The State of Bihar

Dismissed¶17

Manish Kumar v. The State of Bihar

Patna HC6 Aug 2025CR. MISC./30123/2025

Case brief

AI extract

What is this about?

Patna High Court, CRIMINAL MISCELLANEOUS No.30123 of 2025, decided 06-08-2025 by Rajiv Roy, J - bail application rejected. Offences: Sections 64, 308(2), 308(3), 308(4), 308(5), 316(2), 351(2), 352, 3(5) B.N.S. and Section 67 I.T. Act; Naugachia Mahila P.S. Case No. 37 of 2024, District Bhagalpur; informant Satyawati Kumari. Allegations: sexual exploitation on pretext of marriage for almost two years, photos/videos prepared, repeated money demands with threats to make the material viral, and videos/photos sent to the husband after an unmet demand of Rs. 1,00,000/. Keywords: bail refusal, BNS, IT Act Section 67, obscene photos/videos, financial exploitation, Bhagalpur.

What did the court decide?

Considering the submissions of the parties and the material against the petitioner, in which he deliberately tried to ruin the marriage of the lady by sending the explicit photos/videos to her husband, the Court was, for the present, not inclined to extend to him the privilege of bail.

What the court decided

AI extract

Outcome

Dismissed

Issue for consideration

Whether the petitioner, in custody in connection with Naugachia Mahila P.S. Case No. 37 of 2024, deserves to be extended the privilege of bail.

Court's answer

Considering the submissions of the parties and the material against the petitioner, in which he deliberately tried to ruin the marriage of the lady by sending the explicit photos/videos to her husband, the Court was, for the present, not inclined to extend to him the privilege of bail.

Detailed headnote1 paragraphs

Bail refused. The petitioner, Manish Kumar Awadhi Mandal @ Avdhesh Mandal, in custody in Naugachia Mahila P.S. Case No. 37 of 2024 (FIR lodged 24.08.2024 by informant Satyawati Kumari) for offences punishable under Sections 64, 308(2), 308(3), 308(4), 308(5), 316(2), 351(2), 352 and 3(5) of the B.N.S. and Section 67 of the I.T. Act, sought bail. Prosecution case: the informant was sexually exploited on the pretext of marriage for almost two years and videos/photos were prepared/made; after her marriage was arranged and solemnized, the petitioner alongwith the accused persons regularly demanded money or threatened to make the videos/photos viral and the amount was also paid; when the petitioner's demand of Rs. 1,00,000/ was not fulfilled, he sent the videos/photos to her husband, who took her to her parents' home and left her there, leading to the FIR. Counsel for the petitioner urged that the parties were in relationship and there was no forced sexual exploitation; the APP opposed, submitting that the lady was threatened, financially exploited and the videos/photos were made viral by sending them to her husband. Considering the submissions and the material showing that the petitioner deliberately tried to ruin the lady's marriage, the Court declined, for the present, to extend to him the privilege of bail and rejected the bail application. Coram: Rajiv Roy, J; order dated 06-08-2025.

A

IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.30123 of 2025

Arising Out of PS. Case No.-37 Year-2024 Thana- NAUGACHIA MAHILA P.S. DistrictBhagalpur

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

Manish Kumar Awadhi Mandal @ Avdhesh Mandal Resident of VillageJhandapur, P.S-Jhandapur, District-Bhagalpur

... ... Petitioner/s

Versus

The State of Bihar

... ... Opposite Party/s ====================================================== Appearance : For the Petitioner/s : Mr. Ashok Kumar Yadav, Advocate For the Opposite Party/s : Mr. Ganesh Prasad Singh, APP ====================================================== CORAM: HONOURABLE MR. JUSTICE RAJIV ROY ORAL ORDER

3 06-08-2025 Heard the parties.

The petitioner is in custody in connection with

Naugachia Mahila P.S. Case No. 37 of 2024 for the offence punishable under Sections 64, 308(2), 308(3), 308(4), 308(5), 316(2), 351(2), 352 and 3(5) of the B.N.S. and Section 67 of the I.T. Act lodged on 24.08.2024 by the informant, Satyawati Kumari.

As per the prosecution story, the informant alleged that on the pretext of marriage, she was sexually exploited for almost two years and the videos/photos were also prepared/made. Later, as he did not wanted to marry, the family arranged her marriage and it was solemnized. However, the petitioner alongwith the accused persons regularly demanded

Patna High Court CR. MISC. No.30123 of 2025(3) dt.06-08-2025 2/2

money or threatened to make the videos/photos viral and the amount was also paid. However, this petitioner chose to send the videos/photos to her husband as the demand of Rs. 1,00,000/was not fulfilled. The husband thereafter took her to her parent’s home and left there. This led to the FIR.

Though learned counsel for the petitioner tried to impress upon this Court that they were in relationship and there was no forced sexual exploitation, learned APP opposes the prayer submitting that the lady was threatened, financially exploited and ultimately, the videos/photos were made viral by sending it to her husband and as such, he does not deserve bail.

Considering the submissions of the parties as also the material that has come against the petitioner in which he deliberately tried to ruin the marriage of the lady by sending the explicit photos/videos to her husband, in that background, for the present, this Court is not inclined to extend him the privilege of bail.

The bail application stands rejected.

Adnan/-

U T

(Rajiv Roy, J)

Issues for consideration

1 issue framed by the court

AI extract

1.
Whether the petitioner, in custody in connection with Naugachia Mahila P.S. Case No. 37 of 2024, deserves to be extended the privilege of bail.¶15
The court held
Considering the submissions of the parties and the material against the petitioner, in which he deliberately tried to ruin the marriage of the lady by sending the explicit photos/videos to her husband, the Court was, for the present, not inclined to extend to him the privilege of bail.ratio¶16

Statutes considered

10 provisions across 2 enactments

AI extract

B.N.S.64¶11 308(2)¶11 308(3)¶11 308(4)¶11 308(5)¶11 316(2)¶11 351(2)¶11 352¶11 3(5)¶11
I.T. Act67¶11

Procedural history

How this case reached the court

AI extract

Prior proceeding
FIR being Naugachia Mahila P.S. Case No. 37 of 2024 for offences punishable under Sections 64, 308(2), 308(3), 308(4), 308(5), 316(2), 351(2), 352 and 3(5) of the B.N.S. and Section 67 of the I.T. Act.¶11
Prior proceeding
FIR lodged on 24.08.2024 by the informant, Satyawati Kumari.¶11
Prior proceeding
Petitioner shown to be in custody in connection with the said case at the time of the bail hearing.¶10

Parties & counsel

AI extract

petitioner
Manish Kumar Awadhi Mandal @ Avdhesh Mandal¶4
Ashok Kumar Yadav
respondent
The State of Bihar¶7
Ganesh Prasad Singh

Coram

AI extract

Rajiv Royauthor¶8

Case details

As recorded by the court registry

Court: Patna HC
Decided on: 6 Aug 2025 · August
Registered: 30 Apr 2025
Case no.: CR. MISC./30123/2025
CNR: BRHC010401302025
Bench: Rajiv Roy
Disposal: BAIL REJECTED
Case type: CRIMINAL MISCELLANEOUS

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Cite this judgement

Manish Kumar v. The State of Bihar, CR. MISC./30123/2025 (PAT), decided on 6 August 2025.

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

Statutes10

B.N.S.64 · 308(2) · 308(3) · 308(4) · 308(5) · 316(2) · 351(2) · 352 · 3(5)
I.T. Act67

View all statutes

Procedural history3

FIR being Naugachia Mahila P.S. Case No. 37 of 2024 for offences punishable under Sections 64, 308(2), 308(3), 308(4), 308(5), 316(2), 351(2), 352 and 3(5) of the B.N.S. and Section 67 of the I.T. Act.
FIR lodged on 24.08.2024 by the informant, Satyawati Kumari.

View full history

Bench / Coram

Rajiv Roy

Parties & counsel