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Anil Singh @ Anil Kr Singh Vs The State Of Bihar — Anticipatory Bail | Patna HC (2026)

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Patna HC
2026
Anil Singh @ Anil Kr Singh Vs The State Of BiharAnil Singh @ Anil Kr Singh v. The State Of Bihar

Allowed¶26

Anil Singh @ Anil Kr Singh v. The State Of Bihar

Patna HC22 Jun 2026CR. MISC./40071/2026

Case brief

AI extract

What is this about?

Patna High Court, CRIMINAL MISCELLANEOUS No.40071 of 2026, decided 22-06-2026 by Chandra Shekhar Jha, J. Anticipatory bail allowed in Mirganj P.S. Case No.124 of 2026 (Gopalganj) under Section 30(a) Bihar Prohibition and Excise Act, 2022; 25 liters IMFL/country-made liquor recovered; petitioner unnamed in FIR, name surfaced via disclosure of co-accused Vishal Kumar; seizure list disputed (police, not independent, witnesses); petitioner on bail in three other cases; release ordered on Rs.10,000 bond with two like sureties before Exclusive Special Excise Court No.-II, Gopalganj, with four-week surrender window, subject to Section 438(2) CrPC / Section 482(2) BNSS conditions.

What did the court decide?

Anticipatory bail granted: release on bail on furnishing bail bond of Rs.10,000 with two sureties of the like amount each to the satisfaction of the learned Exclusive Special Excise Court No.-II, Gopalganj, upon arrest or surrender within four weeks, subject to conditions under Section 438(2) CrPC / Section 482(2) BNSS.

Why is it important?

Taking note that recovery of illicit liquor prima facie does not appear to have been made from the conscious physical possession of the petitioner, the court found the factual position supportive of granting anticipatory bail. ¶26

What the court decided

AI extract

Outcome

Anticipatory bail granted: release on bail on furnishing bail bond of Rs.10,000 with two sureties of the like amount each to the satisfaction of the learned Exclusive Special Excise Court No.-II, Gopalganj, upon arrest or surrender within four weeks, subject to conditions under Section 438(2) CrPC / Section 482(2) BNSS.

Issue for consideration

Whether the petitioner, apprehending arrest in Mirganj P.S. Case No.124 of 2026 (Section 30(a), Bihar Prohibition and Excise Act, 2022), is entitled to anticipatory bail.

Court's answer

Taking note that recovery of illicit liquor prima facie does not appear to have been made from the conscious physical possession of the petitioner, the court found the factual position supportive of granting anticipatory bail.

Ratio / Principle

Petitioner directed to be released on bail, upon arrest or surrender within four weeks, on furnishing bail bond of Rs.10,000 with two sureties of the like amount each to the satisfaction of the learned Exclusive Special Excise Court No.-II, Gopalganj, subject to conditions under Section 438(2) CrPC / Section 482(2) BNSS.

Detailed headnote1 paragraphs

Anticipatory bail granted - Anil Singh @ Anil Kr. Singh, not named in the FIR but implicated through disclosure of apprehended co-accused Vishal Kumar in Mirganj P.S. Case No.124 of 2026 (Gopalganj) under Section 30(a), Bihar Prohibition and Excise Act, 2022, involving recovery of 25 liters of IMFL/country-made liquor. Patna High Court (Chandra Shekhar Jha, J., 22-06-2026) took note that the recovery prima facie did not appear to be from the petitioner's conscious physical possession and directed his release on bail on a bond of Rs.10,000 with two sureties of the like amount each to the satisfaction of the learned Exclusive Special Excise Court No.-II, Gopalganj, upon arrest or surrender within four weeks, subject to conditions under Section 438(2) CrPC / Section 482(2) BNSS.

A

IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.40071 of 2026

Arising Out of PS. Case No.-124 Year-2026 Thana- MIRGANJ District- Gopalganj

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

Anil Singh @ Anil Kr. Singh, S/o Mangal Singh, R/o Village-Penli, P.S - Mirganj, Dist- Goplaganj.

... ... Petitioner

Versus

The State of Bihar

... ... Opposite Party

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

For the Petitioner/s : Mr. Vinod Pandey, Advocate For the Opposite Party/s : Md. Nazir Ansari, APP

====================================================== CORAM: HONOURABLE MR. JUSTICE CHANDRA SHEKHAR JHA

ORAL ORDER

2 22-06-2026

Heard learned counsel for the petitioner and

learned Additional Public Prosecutor for the State.

The accused/petitioner is not named in the FIR

and apprehending his arrest in connection with Mirganj P.S. Case No.124 of 2026 registered under Section 30(a) of the Bihar Prohibition and Excise Act, 2022.

Allegation against the petitioner is to engage in

illegal trade/manufacturing of illicit liquor, where there is recovery of 25 liters of IMFL/country-made liquor.

It is submitted by learned counsel appearing for

petitioner that the name of this petitioner transpired on the

basis of disclosure made by apprehended co-accused Vishal

Patna High Court CR. MISC. No.40071 of 2026(2) dt.22-06-2026 2/3

Kumar, where admittedly the recovery of illicit liquor was not made from conscious physical possession of this petitioner. It is submitted that the seizure list also appears disputed being not supported by independent witnesses rather by police personnel. While concluding argument, it is submitted that petitioner found involved in three more criminal cases, where he is on bail.

Learned APP opposed the prayer of anticipatory bail to the petitioner.

In view of aforesaid factual submissions and by taking of note of fact as recovery of illicit liquor prima facie not appears to be made from conscious physical possession of this petitioner, accordingly, the petitioner, above-named, in the event of his arrest or surrender in the court below within a period of four weeks from today, is directed to be released on bail on furnishing bail bond of Rs.10,000/(Rupees Ten Thousand) with two sureties of the like amount each to the satisfaction of the learned Exclusive Special Excise Court No.-II, Gopalganj in connection with Mirganj P.S. Case No.124 of 2026, subject to the conditions as laid

Patna High Court CR. MISC. No.40071 of 2026(2) dt.22-06-2026 3/3

down under Section 438(2) of the CrPC/under Section

482(2) of the BNSS.

(Chandra Shekhar Jha, J.)

Sanjeet/-

U T

Issues for consideration

1 issue framed by the court

AI extract

1.
Whether the petitioner, apprehending arrest in Mirganj P.S. Case No.124 of 2026 (Section 30(a), Bihar Prohibition and Excise Act, 2022), is entitled to anticipatory bail.¶25
The court held
Taking note that recovery of illicit liquor prima facie does not appear to have been made from the conscious physical possession of the petitioner, the court found the factual position supportive of granting anticipatory bail.ratio¶26

Statutes considered

3 provisions across 3 enactments

AI extract

Bihar Prohibition and Excise Act, 202230(a)¶17
Code of Criminal Procedure (CrPC)438(2)¶28
Bharatiya Nagarik Suraksha Sanhita (BNSS)482(2)¶29

Procedural history

How this case reached the court

AI extract

Prior proceeding
Petitioner, not named in the FIR, apprehends arrest in Mirganj P.S. Case No.124 of 2026, District Gopalganj, registered under Section 30(a) of the Bihar Prohibition and Excise Act, 2022.¶17
Prior proceeding
Allegation of illegal trade/manufacturing of illicit liquor with recovery of 25 liters of IMFL/country-made liquor.¶19
Prior proceeding
Per counsel, petitioner's name transpired on disclosure of apprehended co-accused Vishal Kumar; recovery admittedly not from petitioner's conscious physical possession; seizure list disputed as unsupported by independent witnesses.¶24
Prior proceeding
Petitioner stated to be involved in three more criminal cases in which he is on bail.¶24

Parties & counsel

AI extract

petitioner
Anil Singh @ Anil Kr. Singh¶4
Vinod Pandey
respondent
The State of Bihar¶7
Md. Nazir Ansari

Coram

AI extract

Chandra Shekhar Jhaauthor¶11

Case details

As recorded by the court registry

Court: Patna HC
Decided on: 22 Jun 2026 · June
Registered: 16 Jun 2026
Case no.: CR. MISC./40071/2026
CNR: BRHC010563682026
Topic: Anticipatory Bail
Bench: Chandra Shekhar Jha
Disposal: BAIL GRANTED
Case type: CRIMINAL MISCELLANEOUS

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Cite this judgement

Anil Singh @ Anil Kr Singh v. The State Of Bihar, CR. MISC./40071/2026 (PAT), decided on 22 June 2026.

The Patna High Court publishes no neutral citation for this judgement — cite it by case number and date of decision.

Statutes3

Bihar Prohibition and Excise Act, 202230(a)
Code of Criminal Procedure (CrPC)438(2)
Bharatiya Nagarik Suraksha Sanhita (BNSS)482(2)

View all statutes

Procedural history4

Petitioner, not named in the FIR, apprehends arrest in Mirganj P.S. Case No.124 of 2026, District Gopalganj, registered under Section 30(a) of the Bihar Prohibition and Excise Act, 2022.
Allegation of illegal trade/manufacturing of illicit liquor with recovery of 25 liters of IMFL/country-made liquor.

View full history

Bench / Coram

Chandra Shekhar Jha

Parties & counsel