Allowed¶22

Sanjay Bhagat v. The State of Bihar

Patna HC6 Feb 2026CR. MISC./78404/2025

Case brief

AI extract

What is this about?

Keywords: bail granted; general and omnibus allegation; last seen suspicion; Sections 137 and 140(3) BNS; Pipra P.S. Case No. 357 of 2024; East Champaran; custody since 23.01.2025; investigation completed; charge-sheet submitted (counsel's submission); bail bond Rs.10,000/- with two sureties; SDJM Sikrahana at Dhaka; Section 437(3) Cr.P.C.; Section 480(3) BNSS; Patna High Court; Chandra Shekhar Jha, J.; decided 06-02-2026; CRL. MISC. No.78404 of 2025.

What did the court decide?

Petitioner Sanjay Bhagat directed to be released on bail in Pipra P.S. Case No. 357 of 2024 on furnishing a bail bond of Rs.10,000/- with two sureties of the like amount each, to the satisfaction of the learned SDJM, Sikrahana at Dhaka, East Champaran/concerned court, subject to conditions under Section 437(3) Cr.P.C./Section 480(3) BNSS. ¶22

Sanjay Bhagat Vs The State of Bihar — Bail and Remand | Patna HC (2026)

What the court decided

AI extract

Outcome

¶22

Issue for consideration

Whether the petitioner, whose implication prima facie rests only on a general and omnibus allegation amounting at best to last-seen suspicion, should be released on bail given that the investigation of the case is completed and he has remained in custody since 23.01.2025.

¶20

Court's answer

The petitioner's implication prima facie appears only on the basis of a general and omnibus allegation — at best a last-seen suspicion — as regards his role alongside other co-accused persons.

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Ratio / Principle

Coupled with the fact that the investigation of the case is already completed and the petitioner has remained in custody since 23.01.2025, the petitioner was directed to be released on bail.

¶20

Key takeaways

Release was ordered on furnishing a bail bond of Rs.10,000/- (Rupees Ten Thousand) with two sureties of the like amount each, to the satisfaction of the learned SDJM, Sikrahana at Dhaka, East Champaran/concerned court.ratio¶22
The bail was made subject to the conditions mentioned under Section 437(3) of the Cr.P.C./Section 480(3) of BNSS.ratio¶22

Detailed headnote1 paragraphs

Patna High Court (Chandra Shekhar Jha, J.), oral order dated 06-02-2026 in CRIMINAL MISCELLANEOUS No.78404 of 2025: bail granted to Sanjay Bhagat in connection with Pipra P.S. Case No. 357 of 2024 (registered for offences under Sections 137 and 140(3) of BNS, District East Champaran). The Court found the petitioner's implication prima facie rested only on a general and omnibus allegation — at best last-seen suspicion — alongside named co-accused persons; coupled with completion of investigation and the petitioner's custody since 23.01.2025, he was directed to be released on a bail bond of Rs.10,000/- (Rupees Ten Thousand) with two sureties of the like amount each, to the satisfaction of the learned SDJM, Sikrahana at Dhaka, East Champaran/concerned court, subject to the conditions under Section 437(3) of the Cr.P.C./Section 480(3) of BNSS. No precedent was cited or relied upon.

¶1

IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.78404 of 2025

¶2

Arising Out of PS. Case No.-357 Year-2024 Thana- PIPRA District- East Champaran

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

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Sanjay Bhagat S/O Late Raghav Bhagat R/O Vill.- Vishunpura, P.S- Pipra, Dist.- East Champaran

... ... Petitioner/s

Versus

The State of Bihar

... ... Opposite Party/s ====================================================== Appearance : For the Petitioner/s : Mr.Abhishek Kumar For the Opposite Party/s : Mr.Uma Shankar Prasad Singh For the Informant : Mr. Krishna Kant Singh ======================================================

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CORAM: HONOURABLE MR. JUSTICE CHANDRA SHEKHAR JHA ORAL ORDER

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2 06-02-2026

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Heard the parties.

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The petitioner seeks bail in connection with Pipra P.S.

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Case No. 357 of 2024 registered for the offence under Sections 137 and 140(3) of BNS.

¶14

The petitioner is named in the F.I.R. and is in custody since 23.01.2025.

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As per FIR, the son of the informant was called from his house on 29.11.2024 at about 5 PM by named co-accused persons where after his mobile phone was found switched off. The informant expressed apprehension that his son might be killed by co-accused Krishna Mahto, as on earlier occasion he threatened his son to kill.

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Learned counsel appearing on behalf of the petitioner submitted that allegation is specific against co-accused Golu

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Patna High Court CR. MISC. No.78404 of 2025(2) dt.06-02-2026 2/3

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Kumar to cause fatal firearm injury and the motorcycle which was used in crime in question also recovered from his possession. It is submitted that allegation against this petitioner is very much general and omnibus and except last seen, nothing incriminating appears against him. While concluding the argument, it is submitted that petitioner is a man of clean antecedent and moreover, investigation of this case is completed, for which charge-sheet has been submitted, as such, there is no chance of tampering with the evidence.

¶19

Learned APP duly assisted by learned counsel for the informant while opposing the prayer of bail submitted that petitioner was engaged in calling son of informant along with other named co-accused persons from his home, where after present occurrence took place.

¶20

In view of aforesaid facts and circumstances as implication of this petitioner prima-facie appears only on the basis of general and omnibus allegation as to call petitioner from his home along with other co-accused persons, at best last seen suspicion, coupled with fact that investigation of this case is already completed, where petitioner remains in custody since 23.01.2025, accordingly petitioner above named, is directed to be released on bail in connection with Pipra P.S. Case No. 357 of

¶21

Patna High Court CR. MISC. No.78404 of 2025(2) dt.06-02-2026 3/3

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2024 on furnishing bail bond of Rs.10,000/- (Rupees Ten Thousand) with two sureties of the like amount each to the satisfaction of learned SDJM, Sikrahana at Dhaka, East Champaran/concerned court, subject to the conditions as mentioned under Section 437(3) of the Cr.P.C/ Section 480(3) of BNSS.

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(Chandra Shekhar Jha, J.)

¶24

S.Tripathi/-

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U T

Sanjay Bhagat v. The State of Bihar

Case brief

What is this about?

What did the court decide?

Sanjay Bhagat 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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