Pappu Kumar @ Pappu Sahni @ Pappu Kumar Sahni Vs The State… — Anticipatory Bail | Patna HC (2026)

Pappu Kumar @ Pappu Sahni @ Pappu Kumar Sahni Vs The State… — Anticipatory Bail | Patna HC (2026)

What the court decided

AI extract

Outcome

Provisional anticipatory bail granted: petitioner to be released on arrest or surrender within six weeks on bail bonds of Rs. 30,000 with two sureties of the like amount each, subject to Section 482(2) BNSS conditions; confirmation conditional on Trial Court verification that his antecedents do not exceed six cases.

Issue for consideration

Whether the petitioner, apprehending arrest in Ahiyapur P.S. Case No. 1184 of 2025 registered for offences under Section 30(a) of the Bihar Excise Act, should be released on anticipatory bail. +1 more

Court's answer

In the event of his arrest or surrender before the learned Trial Court within a period of six weeks, the petitioner is to be released on provisional anticipatory bail in connection with Ahiyapur P.S. Case No. 1184 of 2025.

Ratio / Principle

Release is on furnishing bail bonds of Rs. 30,000 (Rupees Thirty Thousand) with two sureties of the like amount each to the satisfaction of the learned Trial Court where the case is pending.

Key takeaways

The anticipatory bail is subject to the conditions laid down under Section 482(2) of the BNSS.ratio¶18
The Trial Court shall verify the petitioner's criminal antecedents: if more than six cases are found, it will be presumed that the petitioner concealed his antecedents and the provisional anticipatory bail order shall not be confirmed; if only six cases are found, the provisional anticipatory bail order shall be confirmed forthwith.ratio¶21

Detailed headnote1 paragraphs

Anticipatory bail - Bihar Excise Act, S. 30(a) - Ahiyapur P.S. Case No. 1184 of 2025, Muzaffarpur - Alleged recovery of 97.5 litres of liquor from a Hyundai car; petitioner claimed he was not apprehended from the spot, nothing was recovered from his conscious possession, he was not the owner of the seized vehicle, and he was implicated at the instance of a local person - Six prior cases under the Excise Act disclosed - Held: provisional anticipatory bail granted; petitioner to surrender or be arrested within six weeks and furnish bail bonds of Rs. 30,000 with two like sureties, subject to S. 482(2) BNSS conditions - Confirmation made conditional on Trial Court verification of antecedents: if more than six cases found, concealment presumed and order not to be confirmed; if six cases only, to be confirmed forthwith.

IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.34412 of 2026

Arising Out of PS. Case No.-1184 Year-2025 Thana- AHIYAPUR District- Muzaffarpur

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

Pappu Kumar @ Pappu Sahni @ Pappu Kumar Sahni son of Bhogendra Sahni Resident Of Village - Amar Singh Asthan, Shekhpur Dhab, Ps -Ahiyapur District -Muzaffarpur

... ... Petitioner/s

Versus

The State of Bihar

... ... Opposite Party/s

====================================================== Appearance : For the Petitioner/s : Mr. Chandra Shekhar Anand For the Opposite Party/s : Ms. Veena Kumari Jaiswal ====================================================== CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA ORAL ORDER

2 15-05-2026

Heard learned counsel for the petitioner and learned A.P.P. for the State.

The petitioner apprehends his arrest in a case registered for the offences punishable under Section 30(a) of the Bihar Excise Act.

Learned counsel for the petitioner submits that petitioner has antecedent of six cases under the Excise Act and allegation is of recovery of 97.5 liters of liquor from a Hyundai car.

Learned counsel for the petitioner submits that petitioner was not apprehended from the spot as such nothing was recovered from his conscious possession and is not the owner of the seized vehicle and he came to be implicated at the

Patna High Court CR. MISC. No.34412 of 2026(2) dt.15-05-2026 2/3

instance of local person, but then it is submitted that if local person was aware of the involvement of the petitioner in the occurrence then why he did not inform the police prior to institution of the instant FIR which casts an aspersion on the case of the prosecution.

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

Considering the submissions made by the learned counsel for the petitioner, the petitioner above-named, in the event of his arrest or surrender before the learned Trial Court within a period of six weeks from today, be released on Provisional anticipatory bail on furnishing bail bonds of Rs. 30000/- (Rupees Thirty Thousand) 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 Ahiyapur P.S. Case No. 1184 of 2025 subject to the conditions as laid down under Section 482 (2) of the BNSS.

It is made clear that thereafter the learned Trial Court shall verify the criminal antecedent of the petitioner and in the event if it is found that petitioner has antecedent of more than six cases then it would be presumed that petitioner, for the purposes of seeking anticipatory bail, had concealed his

Patna High Court CR. MISC. No.34412 of 2026(2) dt.15-05-2026 3/3

antecedent before this Court, as such, the provisional anticipatory bail order shall not be confirmed, but after verification if it is found that petitioner has antecedent of six cases only, in that event the provisional anticipatory bail order shall be confirmed forthwith.

(Satyavrat Verma, J)

Rishabh/-

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