Supreme Court sets aside anticipatory bail denial order by Justice Satyavrat Verma in a ca se from Govindganj, Motihari

In Chandan Singh @ Chandan Kumar vs. The State of Bihar (2026), Supreme Court's Division Bench of Justices Sanjay Karol and Augustine George Masih passed a 5-page long order dated June 3, 2026, wherein, it concluded: "6. It is not in dispute that the conditions stand fully complied with; the appellant has cooperated during the investigation; he has not threatened or intimidated any of the witnesses; or has tried to influence the investigation in any manner. 7. We have noticed the nature of crime and the manner in which it was allegedly committed. 8. We allow the present appeal by confirming the order dated 21.04.2026, passed by this Court, with a direction to the appellant to continue to cooperate during the investigation/trial and not to seek any unnecessary adjournment. Also, the appellant shall report before the
Investigating Officer every alternate Monday, between 10 a.m. and 11 a.m., till such time the investigation is complete in all respects. 9. If the Investigating Officer/Arresting Officer/Trial Court feels that the investigation/trial is delayed on account of the appellant’s conduct, it shall be open to the Investigating Officer/Arresting Officer/Trial Court to take appropriate steps in accordance with the law, including cancellation of bail. 10. Further, if the appellant possesses a passport, the same shall be surrendered before the Competent Authority/Court until the conclusion of the trial or directed otherwise. 11. The impugned judgment and order dated 24.03.2026 is set aside."

The appellant had challenged the judgment and order dated March 24, 2026 in Chandan Singh @ Chandan Kumar Vs. The State of Bihar”, passed by Justice Stayavrat Verma of the Patna High Court. 

On April 21, 2026, the Supreme Court had passed an order, which reads: "6. In the event of arrest in connection with FIR No. 280 of 2025, registered at Govindganj Police Station, District Motihari, Bihar dated 20.11.2025, the petitioner shall be released on bail by the Investigating/Arresting Officer on such terms and conditions as imposed and found to be just, fair and reasonable."

Earlier, in Chandan Singh @ Chandan Kumar vs. The State of Bihar (2026), Justice Verma had passed a 3-page long order dated March 24, 2026, wherei, he had concluded:"the Court is not inclined to extend the privilege of anticipatory bail to the petitioner. 7. Accordingly, the instant anticipatory bail application stands rejected." The petitioner had approached the High Court apprehending his arrest in a case registered for the offences punishable under Sections 318(4), 303(2), 336(4), 340(1), 340(2), 308(5), 61(2) and 111(1) of the BNS, 2023.  

Ajay Kumar Thakur, the counsel for the petitioner had submitted that petitioner had antecedent of one case and the informant alleged that petitioner called him on his mobile and introduced himself as having business of jewellery and called him to Muzaffarpur for buying jewellery, the informant went to Muzaffarpur and saw jewellery worth crore of rupees and said that he will come back with money, accordingly, the informant along with his friend went to buy jewellery, but before reaching Muzaffarpur, made a call when petitioner asked him to come near Areraj accordingly, the informant along with his friend went to the place where he was called by the petitioner, further the petitioner took him to the hose of Amresh and disclosed that the house is also for sale and showed jewellery, further petitioner in the meantime made a call when 7-8 accused on 3-4 motorcycles came and took Rs. 19 Lakhs along with other articles and started fleeing, when his friend caught an accused who disclosed his name as Surendra and also disclosed that petitioner, Amresh and others are part of organized gang who fled with the articles and cash. 

The counsel for the petitioner had submitted that the petitioner had been falsely implicated in the instant case by the informant, it was also submitted that the mobile from which the informant got a call does not belong to the petitioner. It was submitted that even the informant dealt in business of purchasing looted jewellery. It was further submitted that petitioner was engaged in business with one Neha Kumari, wife of the brother of the petitioner and the informant had given money to Neha but when the deal failed, the instant false case came to be instituted.

A.P.P. for the State had opposed the anticipatory bail application of the petitioner and submitted that Neha is also an accused in the instant case. It was also submitted that if informant was dealing in purchasing looted jewellery in that event the same would surface during the course of investigation and appropriate action would be taken, but then as far as the petitioner was concerned, the mobile may not belong to him, but when informant before reaching Muzaffarpur called him on the mobile from which he had received a call from the petitioner earlier, the same was picked by petitioner again. It was submitted that the informant specifically alleged that petitioner along with others were operating an organized crime. It also submitted that investigation of the case is continuing and if privilege of anticipatory bail is granted to the petitioner, the petitioner may abscond.

Supreme Court sets aside part of conditional bail order by Justice Purnendu Singh

In Mithilesh Kumar Bhagat vs. The State of Bihar & Anr. (2026), Supreme Court's Division Bench of Justices J.B. Pardiwala and K.V. Viswanathan passed a 3-page long order dated February 13, 2026 wherein, it concluded:".....we set aside that part of the order of the High Court by which the High Court has directed the petitioner to appear before the District Mediation Centre for the purpose of mediation. 9. The rest of the part of the order granting anticipatory bail is not touched." 

The Supreme Court recorded that "there are some civil litigations also pending between the parties." Justice Singh too had observed:"4. Considering the nature of dispute to be purely civil in nature and the parties are contesting Civil Suit No. 135 of 2024 for specific performance of contract since 17.03.2025, at
the same time, I find that the parties can resolve their dispute outside the Court amicably by way of mediation. 5. The petitioner is directed to appear before the learned District Court on 25.09.2025 at 10.30 am." As per the allegation made in the FIR, petitioner and his son had committed forgery with the informant by receiving Rs. 55 lacs for executing a piece of land appertaining to Khata No. 130, Khesra Nos. 220 measuring total area two Bigha.

Notably, Justice Purnendu Singh had passed a 3-page long order dated September 10, 2025, wherein, he had concluded: "6. Learned District Court is directed to take necessary action to refer the matter before the learned mediator of the District Mediation Center. 7. Learned Mediator of the District Mediation Center concerned shall make his/her best efforts to settle the dispute amicably between the parties and thereafter submit his/her report before the concerned learned District Court, well within a period of three months, till then, no coercive action shall be taken against the petitioner in connection with the aforesaid case.8. In case of failure on the part of the petitioner to appear on 25.09.2025 at 10.30 am. before the learned District Court or on any date fixed by the learned Mediator, the interim protection granted to the petitioner shall automatically lose its force. 9. In case, the parties fail to reconcile, then in that case, parties may avail appropriate remedy. 10. Accordingly, the present bail application stands disposed of."

Supreme Court observed:"6. The High Court thought fit to grant anticipatory bail but at the same time directed the petitioner to go for mediation. 7. We are of the view that once the High Court was convinced that a case was made out for grant of anticipatory bail, then the Court should not have asked the petitioner-accused to go for mediation." 

The petitioner, an aged person, had prayed for anticipatory bail before the High Court in connection with a Khanpur Police Station case of 2025 registered for the offence punishable under Sections 316(2), 318(4), 338, 336(3), 340(2), 308(1), 308(5) and 61(2) of the Bharatiya Nyaya Sanhita (BNS), 2023, respectively.  Prima facie, the allegations against the petitioner was one of forgery and cheating.