Allowed¶22

Rina Devi v. The Sate of Bihar

Patna HC17 Jun 2026CR. MISC./38723/2026

Case brief

AI extract

What is this about?

Pre-arrest bail; anticipatory bail; Bihar Prohibition and Excise Act Section 30(a); illicit liquor recovery from bushes/open space; Panapur P.S. Case No. 187/2026; District Saran (Chhapra); Section 482(2) BNSS conditions; bail bond Rs. 10,000 with two sureties; criminal antecedent verification clause; Patna High Court CR. MISC. No.38723 of 2026; Justice Purnendu Singh.

What did the court decide?

Pre-arrest bail granted to the petitioner in connection with Panapur P.S. Case No. 187/2026, on furnishing bail bond of Rs. 10,000/- with two sureties of the like amount each, subject to conditions under Section 482(2) of the BNSS; order to lapse if other criminal antecedents are found. ¶22

Rina Devi Vs The Sate of Bihar — Anticipatory Bail | Patna HC (2026)

What the court decided

AI extract

Outcome

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Issue for consideration

Whether the petitioner is entitled to pre-arrest bail in connection with Panapur P.S. Case No. 187/2026, registered under Section 30(a) of the Bihar Prohibition and Excise Act, where the alleged recovery of illicit liquor was made from bushes in an open space.

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Court's answer

Considering the allegations in the FIR and the fact that the alleged recovery of illicit liquor was effected from bushes in an open space easily accessible by anyone, the petitioner has prima facie made out a case to be released on pre-arrest bail.

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Ratio / Principle

The petitioner is directed to be released on pre-arrest bail, in the event of her arrest or surrender before the learned District Court within four weeks, on furnishing a bail bond of Rs. 10,000/- with two sureties of the like amount each, subject to the conditions laid down under Section 482(2) of the BNSS.

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Key takeaways

The learned District Court is to verify the petitioner's criminal antecedents; if she is found involved in other cases as stated in paragraph no.3 of the bail application, this order will automatically lose its force.ratio¶25

Detailed headnote1 paragraphs

Patna High Court (Purnendu Singh, J.), Criminal Miscellaneous No.38723 of 2026, decision dated 17-06-2026: Pre-arrest bail granted to the petitioner in connection with Panapur P.S. Case No. 187/2026 under Section 30(a) of the Bihar Prohibition and Excise Act, where 7 litres of illicit liquor was allegedly recovered from bushes. The Court held that recovery from bushes, being an open space easily accessible by anyone, prima facie entitled the petitioner to pre-arrest bail. Release ordered upon arrest or surrender before the learned District Court within four weeks, on a bail bond of Rs. 10,000/- with two sureties of the like amount each, subject to the conditions under Section 482(2) of the BNSS. The order is to stand automatically vacated if the District Court verifies involvement of the petitioner in other cases as stated in the bail application.

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IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.38723 of 2026

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Arising Out of PS. Case No.-187 Year-2026 Thana- PANAPUR District- Saran

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

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Rina Devi W/O Mokhatar Mahato R/O Village - Rampur Rudra, P.S- Panapur, District - Saran at Chhapra

... ... Petitioner/s

Versus

The Sate of Bihar

... ... Opposite Party/s

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====================================================== Appearance :

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For the Petitioner/s : Mr.Vijaya Laxmi Srivastawa, Advocate For the Opposite Party/s : Ms.Asha Kumari, APP

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

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CORAM: HONOURABLE MR. JUSTICE PURNENDU SINGH ORAL ORDER

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2 17-06-2026

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Heard learned counsel appearing on behalf of the petitioner and learned APP for the State.

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The petitioner seeks pre-arrest bail in connection with Panapur P.S. Case No. 187/2026 registered for the offence(s) punishable under Section 30(a) of the Bihar Prohibition and Excise Act.

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As per the allegation made in the FIR, 7 litres of illicit liquor was recovered from the bushes.

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Learned counsel appearing on behalf of the petitioner submitted that petitioner is innocent and has falsely been implicated in the present case. Learned counsel further submitted that recovery of illicit liquor has been made from the bushes which is an open space and is easily accessible by anyone. Petitioner has no concern either with the place of

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Patna High Court CR. MISC. No.38723 of 2026(2) dt.17-06-2026 2/3

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recovery or with the alleged sized liquor.

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Learned APP for the State vehemently opposed the prayer for grant of pre-arrest bail.

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Having heard the rival submissions made on behalf of the parties and upon perusal of the allegations made in the FIR, coupled with the fact that the alleged recovery of illicit liquor was effected from the bushes, which is an open space and easily accessible by anyone, I am of the opinion that petitioner, has, prima facie, made out a case to be released on pre-arrest bail.

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The petitioner, above named, is directed to be released on pre-arrest bail, in the event of her arrest or surrender before the learned District Court within a period of four weeks from today, on furnishing bail bond of Rs. 10,000/- (Rupees Ten Thousand) with two sureties of the like amount each to the satisfaction of learned Concerned Court where the case is pending in connection with Panapur P.S. Case No. 187/2026, subject to the conditions as laid down under Section 482(2) of the BNSS.

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The learned District Court is directed to verify the criminal antecedent of the petitioner and if it is found that the petitioner is involved in some other cases, as what has been

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Patna High Court CR. MISC. No.38723 of 2026(2) dt.17-06-2026 3/3

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stated in paragraph no.3 of the bail application, this order will automatically lose its force.

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(Purnendu Singh, J)

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Sanjay/-

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U T

Rina Devi v. The Sate of Bihar

Case brief

What is this about?

What did the court decide?

Rina Devi v. The Sate 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

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