The Patna High Court has granted bail to Satyam Kumar in a case involving alleged illegal AK-47 procurement and offences under the Unlawful Activities (Prevention) Act (UAPA). The Division Bench found that the National Investigation Agency (NIA) had not established any digital connection or financial transactions between him and the co-accused. The Court also considered the prolonged custody and slow progress of the trial.
Background
The case arose from an investigation into the alleged procurement and concealment of an AK-47 rifle. According to the prosecution, police apprehended Satyam Kumar and co-accused Vikas Kumar at Muzaffarpur Railway Station on May 7, 2024. An AK-47 rifle butt and a lens allegedly associated with the firearm were said to have been recovered.
The investigation was subsequently taken over by the NIA, and provisions of the UAPA were added. The agency alleged that the accused were connected to a network involved in procuring firearms. Satyam Kumar, however, argued that there was insufficient material linking him to the alleged activities.
He challenged the Special NIA Court's order dated May 11, 2026, rejecting his bail plea. His counsel also pointed out that he had remained in custody since May 2024 and that the trial was progressing slowly.
During the hearing, the Bench asked the NIA to clarify whether its investigation had established financial transactions or digital communications between Satyam Kumar and the other accused. On October 8, 2026, the agency informed the Court that its investigation had found neither.
The judgment records the NIA's position:
“The NIA has not found any financial transaction between this appellant and the co-accused.”
The Court examined the case diary and identified discrepancies concerning the alleged recovery of the lens from Satyam Kumar. Although the order rejecting bail referred to a recovery at the railway station, the seizure records did not establish that the lens had been recovered there. The records instead indicated a seizure at Village Mankauli, approximately two and a half hours after his detention.
The Bench also noted that the only material connecting Satyam Kumar to the other accused was his visit to Dimapur, Nagaland, with his cousin Vikas Kumar.
The Court further observed:
“No financial transaction between this appellant and the co-accused has been found.”
The Bench noted that the appellant had no criminal antecedents and had spent more than two years in custody. Of the 91 witnesses cited in the charge sheets, only two had been examined by the time of the hearing.
After considering the available material, the Court concluded that the circumstances warranted setting aside the order rejecting bail.
The Division Bench of Justice Rajeev Ranjan Prasad and Justice Sunil Dutta Mishra allowed the appeal and directed that Satyam Kumar be released on bail upon furnishing a bond of ₹25,000 with two sureties of the same amount, subject to the satisfaction of the Special Judge, NIA, Patna.
The Court directed him to attend every trial hearing and prohibited him from leaving India without its permission. He must also deposit his passport, if any, with the trial court.
Case Details
- Case Title: Satyam Kumar v. Union of India through National Investigation Agency
- Case Number: Criminal Appeal (DB) No. 787 of 2026
- Judges: Justice Rajeev Ranjan Prasad and Justice Sunil Dutta Mishra
- Decision Date: October 9, 2026
