Allowed¶18

Ranjit Kumar v. The State of Bihar

Patna HC23 Apr 2026CR. MISC./27183/2026

Case brief

AI extract

What is this about?

Anticipatory bail; provisional anticipatory bail; Section 30(a) Bihar Prohibition and Excise (Amendment) Act 2022; Section 482(2) B.N.S.S.; 197.280 litres liquor recovery; vacant premises of Raman; confessional statement of Rajiv; deemed possession and presumed offender done away with post-2018 Excise Act amendment; Saharsa Sadar P.S. Case No.1414/2025; bail bond Rs.500 with two sureties; criminal antecedent verification condition; Patna High Court; Satyavrat Verma, J; decided 23-04-2026.

What did the court decide?

Provisional anticipatory bail granted: upon arrest or surrender within six weeks, release on bail bonds of Rs.500/- with two sureties of the like amount each, subject to Section 482(2) B.N.S.S. conditions; confirmation by the trial court contingent on verification of criminal antecedents. ¶18

Ranjit Kumar Vs The State of Bihar — Anticipatory Bail | Patna HC (2026)

What the court decided

AI extract

Outcome

¶18

Issue for consideration

Whether the petitioner, who apprehends arrest in Saharsa Sadar P.S. Case No.1414/2025 registered for the offence punishable under Section 30(a) of the Bihar Prohibition and Excise (Amendment) Act, 2022, should be granted anticipatory bail.

¶13

Court's answer

In the event of his arrest or surrender within six weeks, the petitioner is to be released on provisional anticipatory bail on furnishing bail bonds of Rs.500/- with two sureties of the like amount each, to the satisfaction of the learned trial court where Saharsa Sadar P.S. Case No.1414/2025 is pending, subject to the conditions laid down under Section 482(2) of the B.N.S.S.

¶18

Ratio / Principle

The learned trial court shall thereafter verify the criminal antecedents of the petitioner; if it is found that the petitioner has antecedents of even one case, it would be presumed that he concealed his antecedents before this Court and the provisional anticipatory bail order shall not be confirmed.

¶19

Key takeaways

If, on verification, the petitioner is found to be a person with clean antecedents, the provisional anticipatory bail order shall be confirmed forthwith.ratio¶21

Detailed headnote1 paragraphs

Anticipatory bail — Patna High Court, Criminal Miscellaneous No.27183 of 2026 (oral order dated 23-04-2026, Satyavrat Verma, J): petitioner apprehended arrest in Saharsa Sadar P.S. Case No.1414/2025 for an offence punishable under Section 30(a) of the Bihar Prohibition and Excise (Amendment) Act, 2022; alleged recovery of 197.280 litres of liquor from vacant premises of one Raman, with counsel submitting that the petitioner was not arrested from the spot, nothing was recovered from his conscious possession, and his implication rested on a custodial confessional statement of Rajiv lacking evidentiary value. The Court granted provisional anticipatory bail: on arrest or surrender within six weeks, release on bail bonds of Rs.500/- with two sureties of the like amount each, subject to the conditions under Section 482(2) of the B.N.S.S.; the trial court was directed to verify criminal antecedents — if even one prior case is found, the provisional order shall not be confirmed (concealment presumed), while verification of clean antecedents leads to confirmation forthwith.

¶1

IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.27183 of 2026

¶2

Arising Out of PS. Case No.-1414 Year-2025 Thana- SAHARSA SADAR District- Saharsa

¶3

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

¶4

Ranjit Kumar Son of Jay Narayan Yadav Resident of Village- Sukhasan, P.S. and District- Saharsa

... ... Petitioner/s

Versus

The State of Bihar

... ... Opposite Party/s ====================================================== Appearance : For the Petitioner/s : Mr. Ashok Kumar For the Opposite Party/s : Mr. Ramesh Chandra ======================================================

¶9

CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA ORAL ORDER

¶10

2 23-04-2026

¶11

Heard learned counsel for the petitioner and learned

¶12

A.P.P. for the State.

¶13

The petitioner apprehends his arrest in a case registered for the offence punishable under Section 30(a) of Bihar Prohibition and Excise (Amendment) Act, 2022.

¶14

Learned counsel for the petitioner submits that petitioner is a person with clean antecedent and allegation is of recovery of 197.280 litres of liquor from vacant premises of Raman. It is next submitted that petitioner was not arrested from the spot as such nothing was recovered from his conscious possession and even alleged recovery is from a place which does not belong to the petitioner and petitioner has no concern or relation with Raman and he came to be implicated based on confessional statement of Rajiv in police custody which does

¶15

Patna High Court CR. MISC. No.27183 of 2026(2) dt.23-04-2026 2/3

¶16

not have any evidentiary value. It is also submitted that after amendment in the Excise Act in the year 2018, the concept of deemed possession and presumed offender has been done away with.

¶17

Learned A.P.P. for the State opposes the prayer for anticipatory bail of the petitioner.

¶18

Considering the submissions made by the learned counsel for the petitioner, the petitioner above-named, in the event of his arrest or surrender within a period of six weeks from today, be released on provisional anticipatory bail on furnishing bail bonds of Rs.500/- (Rupees five hundred) with two sureties of the like amount each to the satisfaction of the learned trial court where the case is pending/successor court in connection with Saharsa Sadar P.S. Case No.1414/2025, subject to the conditions as laid down under Section 482(2) of the B.N.S.S.

¶19

It is made clear that the learned trial court thereafter shall verify the criminal antecedents of the petitioner and in the event if it is found that petitioner has antecedent of even one case, in that event, it would be presumed that petitioner had concealed his antecedent before this court, as such, the provisional anticipatory bail order shall not be confirmed but if

¶20

Patna High Court CR. MISC. No.27183 of 2026(2) dt.23-04-2026 3/3

¶21

on verification it is found that petitioner is a person with clean antecedent, in that event the provisional anticipatory bail order shall be confirmed forthwith.

¶22

(Satyavrat Verma, J)

¶23

amit/-

¶24

U T

Ranjit Kumar v. The State of Bihar

Case brief

What is this about?

What did the court decide?

Ranjit Kumar v. The State of Bihar

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

Issues for consideration

Statutes considered

Procedural history

Parties & counsel

Coram

Case details

Similar cases

Kiran Devi Vs The State of Bihar

Badal Kumar Vs The State of Bihar

Sanjay Mahto Vs The State of Bihar

Kiran Devi Vs The State of Bihar

Ram Kumar Mahto Vs The State of Bihar

Bhuar Ray @ Nirmal Ray Vs The State of Bihar