Allowed¶17

Manohar Ray @ Manohar Kumar v. The State of Bihar

Patna HC24 Jul 2026CR. MISC./50887/2026

Case brief

AI extract

What is this about?

Anticipatory bail; provisional anticipatory bail; Section 30(a) Bihar Excise Act; Section 482 (2) BNSS; Bhagwanpur P.S. Case No. 272 of 2025; Vaishali; liquor recovery 1745.28 liters; truck; six excise antecedents; concealment of antecedents; conditional confirmation; Manohar Ray @ Manohar Kumar; Satyavrat Verma, J.; Patna High Court; 24-07-2026.

What did the court decide?

Provisional anticipatory bail - release upon arrest or surrender within six weeks on bail bond of Rs. 30000/- with two sureties of the like amount each, subject to Section 482 (2) BNSS conditions; confirmation contingent on Trial Court verification of antecedents (forthwith confirmation if exactly six cases; no confirmation if more than six). ¶17

Manohar Ray @ Manohar Kumar 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 Bhagwanpur P.S. Case No. 272 of 2025 registered for offences under Section 30(a) of the Bihar Excise Act, should be released on anticipatory bail.

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Ratio / Principle

Provisional anticipatory bail granted: in the event of arrest or surrender before the learned Trial Court within six weeks, the petitioner is to be released on furnishing bail bonds of Rs. 30000/- with two sureties of the like amount each, to the satisfaction of the learned Trial Court where the case is pending/successor court, subject to the conditions laid down under Section 482 (2) of the BNSS.

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Key takeaways

Confirmation made conditional on antecedent verification: the learned Trial Court shall verify the petitioner's criminal antecedents; if more than six cases are found, it will be presumed the petitioner concealed his antecedents before this Court and the provisional anticipatory bail order shall not be confirmed.ratio¶18
If verification establishes that the petitioner has antecedents of six cases only, the provisional anticipatory bail order shall be confirmed forthwith.ratio¶20

Detailed headnote1 paragraphs

Patna High Court (Satyavrat Verma, J.), Criminal Miscellaneous No. 50887 of 2026, order dated 24-07-2026: Anticipatory bail sought in connection with Bhagwanpur P.S. Case No. 272 of 2025 (District Vaishali) for offences punishable under Section 30(a) of the Bihar Excise Act, involving alleged recovery of 1745.28 liters of liquor from a truck; counsel asserted six prior excise antecedents and denial of conscious possession or ownership of the seized vehicle. The court granted PROVISIONAL ANTICIPATORY BAIL: upon arrest or surrender before the learned Trial Court within six weeks, release on a bail bond of Rs. 30,000/- with two sureties of like amount each, subject to Section 482 (2) of the BNSS. Confirmation was made conditional on the Trial Court verifying criminal antecedents: if more than six cases are found, concealment of antecedents before the Court will be presumed and the provisional order shall not be confirmed; if exactly six cases are found, confirmation follows forthwith.

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IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.50887 of 2026

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Arising Out of PS. Case No.-272 Year-2025 Thana- BHAGWANPUR District- Vaishali

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

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Manohar Ray @ Manohar Kumar Son of Rajdev Ray @ Raj Dev Rai @ Raju Ray R/o Village- Mahua Singh Ray, P.S.- Mahua, District- Vaishali.

... ... Petitioner/s

Versus

The State of Bihar

... ... Opposite Party/s ====================================================== Appearance : For the Petitioner/s : Mr. Anish Kumar For the Opposite Party/s : Mr. Tarkeshwar Nath Thakur ====================================================== CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA ORAL ORDER

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2 24-07-2026

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

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

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Learned counsel for the petitioner submits that petitioner has antecedent of six cases under the Excise Act and allegation is of recovery of 1745.28 liters of liquor from a truck.

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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 based on secret information which is the easiest way to implicate someone. It is also submitted that once an accused is implicated

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Patna High Court CR. MISC. No.50887 of 2026(2) dt.24-07-2026 2/3

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in a case relating to excise, the police starts implicating mechanically either at the instance of Chowkidar , local person, confessional statement or secret information without holding a proper investigation. It is next submitted that petitioner earlier also in similar manner came to be implicated in cases relating to Excise.

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

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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 Bhagwanpur P.S. Case No. 272 of 2025 subject to the conditions as laid down under Section 482 (2) of the BNSS.

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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

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Patna High Court CR. MISC. No.50887 of 2026(2) dt.24-07-2026 3/3

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purposes of seeking anticipatory bail, had concealed his 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.

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(Satyavrat Verma, J)

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Rishabh/-

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U T

Manohar Ray @ Manohar Kumar v. The State of Bihar

Case brief

What is this about?

What did the court decide?

Manohar Ray @ Manohar Kumar v. The State of Bihar

Case brief

What is this about?

What did the court decide?

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What the court decided

Issues for consideration

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