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Saddam Sai @ Saddam Hussain Vs The State of Bihar — Patna HC (2026) — LawSathi Research

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Patna HC
2026
Saddam Sai @ Saddam Hussain Vs The State of BiharSaddam Sai @ Saddam Hussain v. The State of Bihar

Dismissed¶18

Saddam Sai @ Saddam Hussain v. The State of Bihar

Patna HC15 Jan 2026CR. MISC./88764/2025

Case brief

AI extract

What is this about?

Patna High Court, CR. MISC. No.88764 of 2025, decided 15-01-2026 by Anil Kumar Sinha, J. Anticipatory bail rejected; Kopa P.S. Case No. 211 of 2025, District Saran; offences under Sections 126(2), 74, 75, 78 and 96, Bhartiya Nyaya Sanhita, 2023; kidnapping of minor girl dated 10.08.2025; co-accused Laxman Sah and Badshah Sai; molestation and obscene acts with photographs; victim's Section 180 statement before J.M.F.C. Chapra denying kidnapping and claiming voluntary departure to Delhi; statements under Sections 180 and 183 held supportive of allegation; finding of Additional Sessions Judge, Second, Chhapra upheld; prayer for anticipatory bail rejected.

What did the court decide?

The Court found no reason to differ with the finding of the learned Additional Sessions Judge, Second, Chhapra, that the victim girl had supported the allegation in her statement recorded under Sections 180 and 183.

What the court decided

AI extract

Outcome

Dismissed

Issue for consideration

Whether the petitioner, arraigned in Kopa Police Station Case No. 211 of 2025 for offences under Sections 126(2), 74, 75, 78 and 96 of the Bhartiya Nyaya Sanhita, 2023, is entitled to anticipatory bail.

Court's answer

The Court found no reason to differ with the finding of the learned Additional Sessions Judge, Second, Chhapra, that the victim girl had supported the allegation in her statement recorded under Sections 180 and 183.

Ratio / Principle

Considering the nature of the allegation and the impugned order, the Court was not inclined to grant the petitioner the privilege of anticipatory bail.

Detailed headnote1 paragraphs

Anticipatory bail – rejected. Application in Criminal Miscellaneous No.88764 of 2025 arising out of Kopa P.S. Case No. 211 of 2025 (District Saran), disclosing offences under Sections 126(2), 74, 75, 78 and 96 of the Bhartiya Nyaya Sanhita, 2023, concerning the alleged kidnapping of the informant's minor daughter on 10.08.2025 by co-accused Laxman Sah with the help of the petitioner Saddam Sai @ Saddam Hussain and Badshah Sai, and alleged molestation and obscene acts photographed as evidence. Counsel for the petitioner relied on the victim's statement under Section 180 before the J.M.F.C., Chapra, in which she denied kidnapping and said she went to Delhi voluntarily. The learned Additional Sessions Judge, Second, Saran, Chhapra had concluded in the impugned order that the victim supported the allegation in her statement recorded under Sections 180 and 183. Holding no reason to differ with that finding, and considering the nature of the allegation, the Court declined anticipatory bail and the prayer stood rejected (Anil Kumar Sinha, J).

A

IN THE HIGH COURT OF JUDICATURE AT PATNA CRIMINAL MISCELLANEOUS No.88764 of 2025

Arising Out of PS. Case No.-211 Year-2025 Thana- KOPA District- Saran

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

Saddam Sai @ Saddam Hussain Son of Babujan Sai Resident of VillagePiyano, P.O.- Anwal, P.S.- Kopa, District- Saran (Chapra), Bihar

... ... Petitioner/s

Versus

The State of Bihar

... ... Opposite Party/s ====================================================== Appearance : For the Petitioner/s : Mr. ajendra Nath Ojha, Advocate For the Opposite Party/s : Mr. Pramod Kumar Pandey, A.P.P. ======================================================

CORAM: HONOURABLE MR. JUSTICE ANIL KUMAR SINHA ORAL ORDER

2 15-01-2026

Heard learned Counsel for the petitioner and learned Additional Public Prosecutor for the State.

2. This application, for grant of anticipatory bail, arises out of Kopa Police Station Case No. 211 of 2025, disclosing offences under Sections 126(2), 74, 75, 78 and 96 of the Bhartiya Nyaya Sanhita, 2023.

3. The prosecution case, as per the First Information Report, the informant alleged that on 10.08.2025 his minor daughter was kidnapped by co-accused Laxman Sah with the help of his friends Saddam Sai (petitioner) and Badshah Sai and she has not been traceable. It is alleged that co-accused Laxman Sah lured his daughter for breakfast and then to a garden, where he and his friends, molested her and performed obscene acts, photos of which are also available as evidence

4. Learned counsel for the petitioner submits that

Patna High Court CR. MISC. No.88764 of 2025(2) dt.15-01-2026 2/2

petitioner is innocent and has falsely been implicated in this case due to village politics. The petitioner has not committed any offence in the manner alleged and the allegation levelled against the petitioner is false and concocted. Learned counsel further submits that according to the knowledge of petitioner, under Section 180, the statement of the victim girl has been recorded in the Court before learned J.M.F.C, Chapra in which she refused her kidnapping and said that she went to Delhi voluntarily and returned her home with her own sweet will.

5. Considering the nature of allegation and the impugned order, the learned Additional Sessions Judge, Second, Saran, Chhapra, has come to the conclusion that the victim girl has supported the allegation in her statement recorded under Sections 180 and 183, I do not find any reason to differ with the finding of learned Additional Sessions Judge, Second, Chhapra, accordingly, I am not inclined to grant the petitioner privilege of anticipatory bail.

6. The prayer for anticipatory bail stands rejected.

(Anil Kumar Sinha, J)

Siwani/-

U T

Issues for consideration

1 issue framed by the court

AI extract

1.
Whether the petitioner, arraigned in Kopa Police Station Case No. 211 of 2025 for offences under Sections 126(2), 74, 75, 78 and 96 of the Bhartiya Nyaya Sanhita, 2023, is entitled to anticipatory bail.¶12
The court held
The Court found no reason to differ with the finding of the learned Additional Sessions Judge, Second, Chhapra, that the victim girl had supported the allegation in her statement recorded under Sections 180 and 183.ratio¶17

Statutes considered

7 provisions across 3 enactments

AI extract

Bhartiya Nyaya Sanhita, 2023126(2)¶12 74¶12 75¶12 78¶12 96¶12
Section 180180¶16
Sections 180 and 183180, 183¶17

Procedural history

How this case reached the court

AI extract

Order under challenge
Order of the learned Additional Sessions Judge, Second, Saran, Chhapra (referred to in the judgment as 'the impugned order'), whereby the said court came to the conclusion that the victim girl had supported the allegation in her statement recorded under Sections 180 and 183.¶17
Additional Sessions Judge, Second, Saran, Chhapra
Prior proceeding
Kopa Police Station Case No. 211 of 2025, Thana Kopa, District Saran, registered disclosing offences under Sections 126(2), 74, 75, 78 and 96 of the Bhartiya Nyaya Sanhita, 2023.¶2
Prior proceeding
As per the FIR, on 10.08.2025 the informant's minor daughter was allegedly kidnapped by co-accused Laxman Sah with the help of his friends Saddam Sai (petitioner) and Badshah Sai and remained untraceable; it is further alleged that Laxman Sah lured her to a garden where he and his friends molested her and performed obscene acts, photographs of which are available as evidence.¶13
Prior proceeding
According to the petitioner, the victim girl's statement was recorded under Section 180 before the learned J.M.F.C., Chapra, in which she denied being kidnapped and stated that she went to Delhi voluntarily and returned home of her own will.¶16

Parties & counsel

AI extract

petitioner
Saddam Sai @ Saddam Hussain Son of Babujan Sai Resident of VillagePiyano, P.O.- Anwal, P.S.- Kopa, District- Saran (Chapra), Bihar¶4
ajendra Nath Ojha
respondent
The State of Bihar¶7
Pramod Kumar Pandey

Coram

AI extract

Anil Kumar Sinhaauthor¶9

Case details

As recorded by the court registry

Court: Patna HC
Decided on: 15 Jan 2026 · January
Registered: 16 Dec 2025
Case no.: CR. MISC./88764/2025
CNR: BRHC011293492025
Bench: Anil Kumar Sinha
Disposal: BAIL REJECTED
Case type: Criminal Miscellaneous

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Cite this judgement

Saddam Sai @ Saddam Hussain v. The State of Bihar, CR. MISC./88764/2025 (PAT), decided on 15 January 2026.

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

Statutes7

Bhartiya Nyaya Sanhita, 2023126(2) · 74 · 75 · 78 · 96
Section 180180
Sections 180 and 183180, 183

View all statutes

Procedural history4

Order of the learned Additional Sessions Judge, Second, Saran, Chhapra (referred to in the judgment as 'the impugned order'), whereby the said court came to the conclusion that the victim girl had supported the allegation in her statement recorded under Sections 180 and 183.Additional Sessions Judge, Second, Saran, Chhapra
Kopa Police Station Case No. 211 of 2025, Thana Kopa, District Saran, registered disclosing offences under Sections 126(2), 74, 75, 78 and 96 of the Bhartiya Nyaya Sanhita, 2023.
As per the FIR, on 10.08.2025 the informant's minor daughter was allegedly kidnapped by co-accused Laxman Sah with the help of his friends Saddam Sai (petitioner) and Badshah Sai and remained untraceable; it is further alleged that Laxman Sah lured her to a garden where he and his friends molested her and performed obscene acts, photographs of which are available as evidence.

View full history

Bench / Coram

Anil Kumar Sinha

Parties & counsel