Allowed¶20

Manoj Manjhi v. The State of Bihar

Anticipatory bail – Section 482, Bharatiya Nagarik Suraksha Sanhita, 2023

Patna HC4 Jun 2026CR. MISC./36493/2026

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Case brief

AI extract

What is this about?

Patna High Court, CR. MISC. No.36493 of 2026, decided 04-06-2026 by Dr. Anshuman, J. Anticipatory bail under Section 482 BNSS, 2023 granted in excise case under Section 30(a) Bihar Prohibition and Excise (Amendment) Act, 2022 (Maner P.S. Case No. 119/2026; 42.5 litres country liquor recovery). Clean antecedents conceded by APP; bail bond Rs. 30,000/-; conditions under Section 482(2) BNSS; antecedent verification and non-delay in acceptance of bail bonds.

What did the court decide?

Anticipatory bail granted to the petitioner in connection with Maner P.S. Case No. 119/2026, on furnishing bail bond of Rs. 30,000/- to the satisfaction of learned Special (Excise), Danapur, Patna, subject to conditions under Section 482(2) BNSS, 2023 and the antecedent-verification condition. ¶20

Manoj Manjhi Vs The State of Bihar — Anticipatory Bail | Patna HC (2026)

What the court decided

AI extract

Outcome

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Issue for consideration

Whether the petitioner, apprehending arrest in Maner P.S. Case No. 119 of 2026 registered under Section 30(a) of the Bihar Prohibition and Excise (Amendment) Act, 2022, should be released on anticipatory bail under Section 482 of the BNSS, 2023.

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Court's answer

The petitioner is to be released on anticipatory bail, in the event of arrest or surrender before the learned Court below within 4 weeks, on furnishing bail bond of Rs. 30,000/- as mentioned in Section 2(1)(d) of the BNSS, 2023 to the satisfaction of learned Special (Excise), Danapur, Patna, in connection with Maner P.S. Case No. 119/2026, subject to conditions under Section 482(2) of the BNSS, 2023.

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Ratio / Principle

The Trial Court shall verify the criminal antecedent of the petitioner, and if at any stage it is found that the petitioner concealed his criminal antecedent, the Trial Court shall take steps for cancellation of the bail bond.

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Key takeaways

Acceptance of bail bonds in terms of the order shall not be delayed for purpose of, or in the name of, verification of antecedents.ratio¶23

Detailed headnote1 paragraphs

Anticipatory bail — Section 482, Bharatiya Nagarik Suraksha Sanhita, 2023 — Excise offence under Section 30(a), Bihar Prohibition and Excise (Amendment) Act, 2022 (Maner P.S. Case No. 119 of 2026, lodged 09.02.2026; alleged total recovery of 42.5 litres of country made liquor). Counsel for petitioner submitted the recovery was from the house of Surju Manjhi (petitioner's uncle), whose house is 500 meters from the petitioner's house, and that the petitioner's antecedents are clean; the APP opposed bail but fairly conceded the antecedent is clean. Held: petitioner to be released on anticipatory bail in the event of arrest or surrender within 4 weeks, on bail bond of Rs. 30,000/- (Section 2(1)(d) BNSS) before learned Special (Excise), Danapur, Patna, subject to Section 482(2) BNSS conditions; Trial Court to verify criminal antecedents and take steps for cancellation of bail bond if concealment is found at any stage, but acceptance of bail bonds shall not be delayed for purpose of or in the name of verification.

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IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.36493 of 2026

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Arising Out of PS. Case No.-119 Year-2026 Thana- MANER District- Patna

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

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Manoj Manjhi Son of Late Birju Manjhi @ Shambhu Manjhi @ Jok Manjhi Resident of Village- Ajad Nagar, Sattar, Post- Sattar, P.S.- Maner, DistrictPatna

... ... Petitioner/s

Versus

The State of Bihar

... ... Opposite Party/s

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

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CORAM: HONOURABLE MR. JUSTICE DR. ANSHUMAN ORAL ORDER

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2 04-06-2026 The Court proceeding is being conducted through

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virtual mode.

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Heard Learned Counsel for the petitioner and Learned APP for the State.

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The present criminal miscellaneous application has been filed under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (hereinafter referred to as ‘the BNSS, 2023’) for grant of anticipatory bail to the petitioner who apprehends arrest in connection with Maner P.S. Case No. 119 of 2026, lodged on 09.02.2026, under Section 30(a) of the Bihar Prohibition and Excise (Amendment) Act, 2022.

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As per the prosecution, total recovery of 42.5 litres of country made liquor has been made which is the subject

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Patna High Court CR. MISC. No.36493 of 2026(2) dt.04-06-2026 2/3

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matter of the present case.

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Learned Counsel for the petitioner submits that the petitioner is innocent and has committed no offence. Counsel submits that recovery has been made from the house of Surju Manjhi. The house of the petitioner is 500 meter away from his uncle’s house. Counsel submits that the criminal antecedent of the petitioner is clean. Counsel further submits that petitioner is ready to fulfill all the conditions whatsoever shall be imposed upon him.

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Learned APP for the State opposes the prayer for bail of the petitioner but fairly submits that the antecedent of the petitioner is clean.

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As such, in the present facts and circumstances of this case, let the above named petitioner be released on anticipatory bail, in the event of arrest or surrender before the learned Court below within a period of 4 weeks from today, on furnishing bail bond of Rs.30,000/- (Rupees Thirty Thousand) as mentioned in Section 2(1)(d) of the BNSS, 2023 to the satisfaction of learned Special (Excise), Danapur, Patna, in connection with Maner P.S. Case No. 119/2026, subject to the conditions as laid down U/s 482(2) of the BNSS , 2023.

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And further condition that the Trial Court shall

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Patna High Court CR. MISC. No.36493 of 2026(2) dt.04-06-2026 3/3

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verify the criminal antecedent of the petitioner and in case at any stage it is found that the petitioner has concealed his criminal antecedent, the Trial Court shall take step for cancellation of bail bond of the petitioner. However, the acceptance of bail bonds in terms of the above mentioned order shall not be delayed for purpose of or in the name of verification.

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Mkr./Bipin/-

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U T

Manoj Manjhi v. The State of Bihar

Case brief

What is this about?

What did the court decide?

Manoj Manjhi v. The State of Bihar

Case brief

What is this about?

What did the court decide?

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What the court decided

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