Aditya Singh Rana vs. The State Of Bihar

Held

The Court denied the petitioner's prayer for regular bail. It found that there was a direct allegation against the petitioner as a named accused. The materials on record suggested the petitioner's involvement in providing a forged NOC for the vehicle in question, which facilitated the sanction of finance by Shriram Finance. The Court considered the allegation of forgery to be serious in nature. Furthermore, the Court took into account the petitioner's criminal antecedents, which were described as similar in nature, leading to the conclusion that he was not inclined to grant bail. The Court did not expressly leave any issue undecided.

Facts

The petitioner, Aditya Singh Rana, sought bail in a case registered under Sections 318(4), 338, and 336(3) of the BNS. The informant alleged that on February 14, 2025, he purchased a vehicle from M/s Maa Vindhyavasini Car and Bike Point, receiving a false No Objection Certificate (NOC). The vehicle was previously financed by Chola Mandalam Finance Company with outstanding installments, preventing a genuine NOC. The petitioner claimed false implication, stating the business owner, Sonu Kumar Pandey, managed all operations and the petitioner had no access to or knowledge of the forged NOC. The prosecution countered by referring to a complaint filed by the petitioner where he admitted to being the proprietor of the car business and receiving payment, including GST, into his personal account.

Key Issues

1. Whether the petitioner is entitled to regular bail in connection with Udwantnagar P.S. Case No. 337 of 2026, considering the allegations of forgery and his criminal antecedents? The petitioner argued that he was falsely implicated due to a prior grudge and had no role in generating or using the forged NOC, as all business operations were handled by the sole proprietor, Sonu Kumar Pandey. He relied on the GST registration and Udyam Registration Certificate showing Sonu Kumar Pandey as the owner. The petitioner also highlighted his five criminal antecedents and his custody since July 13, 2026. The State and informant opposed the bail, pointing to a complaint filed by the petitioner where he acknowledged being the proprietor of the car business and receiving the sale proceeds, including GST, into his personal account. They contended this showed his active involvement in the transaction and the alleged offense, and that his criminal antecedents indicated he was a habitual offender.