Dismissed¶18

Sajan Kumar v. The State of Bihar

Patna HC15 Apr 2026CR. MISC./11059/2026

Case brief

AI extract

What is this about?

Sajan Kumar v. State of Bihar; Patna High Court CRIMINAL MISCELLANEOUS No.11059 of 2026; oral order dated 15-04-2026; Justice Ashok Kumar Pandey; bail application refused at this stage; Bakhari P.S. Case No.447 of 2025, District Begusarai; BNS Sections 140(4), 61(2), 64 & 3(5); ITP Act Sections 3, 4 & 5; carrying girls forcefully; forced prostitution; harbouring victims; Section 183 BNSS statements of arrested victims; Pushpa Devi; renewal of bail prayer after six months if trial not concluded.

What did the court decide?

No bail at this stage; petitioner permitted to renew his prayer for bail after six months if the trial is not concluded. ¶18

Sajan Kumar Vs The State of Bihar — Patna HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

No bail at this stage; petitioner permitted to renew his prayer for bail after six months if the trial is not concluded.

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Issue for consideration

Whether bail should be granted to petitioner Sajan Kumar in connection with Bakhari P.S. Case No.447 of 2025, registered for offences under Sections 140(4), 61(2), 64 & 3(5) of the BNS and Sections 3, 4 & 5 of the ITP Act.

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Court's answer

Having heard learned counsel for the parties and considering the facts and circumstances of the case, the court declined to grant bail to the petitioner at this stage.

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Ratio / Principle

The petitioner may renew his prayer for bail after six months, if the trial is not concluded.

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Detailed headnote1 paragraphs

Bail refused at this stage with liberty to renew after six months. Patna High Court, Criminal Miscellaneous No.11059 of 2026 (oral order dated 15-04-2026), Hon'ble Mr. Justice Ashok Kumar Pandey: petitioner Sajan Kumar sought bail in Bakhari P.S. Case No.447 of 2025, District Begusarai, registered for offences under Sections 140(4), 61(2), 64 & 3(5) of the BNS and Sections 3, 4 & 5 of the ITP Act. Prosecution case: on information that the petitioner along with others were carrying girls forcefully and assaulting them, police reached the spot; the petitioner along with others was arrested and two ladies were also arrested. Defence counsel submitted that the main thrust of allegation was against the petitioner's father, and that the two arrested victims' Section 183 BNSS statements implicated the petitioner only in having caught one victim while she attempted to flee away; learned APP opposed, submitting that victim Pushpa Devi specifically stated the petitioner caught her while she was attempting to flee, brought her to the house where they were forced to do prostitution, and that the allegation against the petitioner is of harbouring the victims from moving away from the house. Considering the facts and circumstances, the court was not inclined to grant bail at this stage, but held that the petitioner may renew his prayer for bail after six months if the trial is not concluded.

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IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.11059 of 2026

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Arising Out of PS. Case No.-447 Year-2025 Thana- BAKHARI District- Begusarai

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

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Sajan Kumar Son of Sanjay Khalifa R/O Village- Nadailghat, P.S.- Bakhari, District- Begusarai

... ... Petitioner/s

Versus

The State of Bihar

... ... Opposite Party/s ====================================================== Appearance : For the Petitioner/s : Mr. Sanjay Kumar, Advocate For the Opposite Party/s : Mr. Sanjay Kumar Pandey, APP ======================================================

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CORAM: HONOURABLE MR. JUSTICE ASHOK KUMAR PANDEY ORAL ORDER

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3 15-04-2026

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Heard learned counsel for the petitioner and learned APP for the State.

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2. The petitioner has prayed for bail in connection with Bakhari P.S. Case No.447 of 2025 registered for the offence punishable under Sections 140(4), 61(2), 64 & 3(5) of the BNS and under Sections 3, 4 & 5 of the ITP Act.

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3. The case of the prosecution, in short, is that police received an information that the petitioner along with others were carrying girls forcefully and were assaulting them. On this information, police reached there. It is further alleged that petitioner along with others was arrested and two ladies were also arrested.

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4. Learned counsel appearing on behalf of the petitioner has submitted that from perusal of the FIR it will transpire that the main thrust of allegation is against the father of the petitioner as

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Patna High Court CR. MISC. No.11059 of 2026(3) dt.15-04-2026 2/2

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he was indulged in the offence of human trafficking and prostitution thereafter. Learned counsel for the petitioner has further submitted that during course of investigation both the victim who were arrested have given their statement under Section 183 of the BNSS and they have not implicated anything except that the petitioner has caught one of the victim while she was attempting to flee away.

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5. Countering this, learned APP for the State has vehemently opposed the bail and has submitted that victim Pushpa Devi has specifically stated that when she was attempting to flee away, she was being caught by the petitioner and was brought to the house where they were forced to do prostitution. Learned APP has further submitted that the allegation against the petitioner is that of harboring the victims from moving away from the house.

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6. Having heard learned counsel for the parties and considering the facts and circumstances of the case, I am not inclined to grant bail to the petitioner at this stage, however, the petitioner may renew his prayer for bail after six months, if the trial is not concluded.

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(Ashok Kumar Pandey, J)

Sajan Kumar v. The State of Bihar

Case brief

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Sajan Kumar v. The State of Bihar

Case brief

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What did the court decide?

Why is it important?

What the court decided

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