Patna High Court
Satish Kumar Gautam @ Satish MahtoversusThe State of Bihar
- Decided
- Disposal
- BAIL GRANTED
- Bench
- SOURENDRA PANDEY
Holding
The appellate court set aside the trial court’s denial of bail and granted bail to the appellant with conditions.
Summary
Satish Kumar Gautam was charged under several IPC provisions and the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act for allegedly assaulting and humiliating a woman named Rinku Devi. The trial court rejected his bail application, but the appellant appealed under Section 14(A)(2) of the SC/ST POA Act. The appellant argued that the post‑mortem report showed no external injuries and that a forensic report attributed the death to cardiogenic shock, contending he had no role in the alleged offence. The Special Public Prosecutor opposed bail. The Patna High Court set aside the trial court’s order, granting bail on a Rs.10,000 bond with two sureties and imposing conditions such as personal appearance in court and verification of antecedents. The appeal was allowed, and the bail order was issued subject to the stipulated conditions.
Issues considered
- Whether the appellant is entitled to bail under Section 14(A)(2) of the SC/ST (Prevention of Atrocities) Act despite the serious nature of the allegations.
- Whether the medical and forensic evidence negates the prosecution’s case and justifies release on bail.
- Whether the appellant’s criminal antecedents and the nature of the offence warrant denial of bail.
Legislation cited
- Indian Penal Code — s. 103(1), 115(2), 126(2), 352, 76
- Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 — s. 14(A)(2)
Subjects
- bail
- SC/ST (Prevention of Atrocities) Act
- Section 14(A)(2)
- IPC offences
- post‑mortem report
- forensic report
- criminal appeal
- scheduled castes
- scheduled tribes
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL APPEAL (SJ) No.2410 of 2025
Arising Out of PS. Case No.-25 Year-2024 Thana- SC/ST District- Jamui
======================================================
Satish Kumar Gautam @ Satish Mahto S/O Kailash Mahto R/O Village-
Amrath, PS- Jamui, Distt- Jamui
... ... Appellant/s
Versus
The State of Bihar Bihar
... ... Respondent/s
======================================================
Appearance :
For the Appellant/s : Mr. Satya Prakash Parasar, Advocate
For the Respondent/s : Ms. Usha Kumari 1, Spl. PP
======================================================
CORAM: HONOURABLE MR. JUSTICE SOURENDRA PANDEY
ORAL ORDER
4 09-01-2026 At the outset, learned counsel for the appellant
seeks permission to make necessary corrections in
paragraph no. 1 of the bail application.
2. Prayer is accorded.
3. Heard learned counsel for the appellant and
learned Special Public Prosecutor for the State.
4. Despite the notice having been validly served,
no one appears on behalf of the Respondent No. 2.
5. This is an appeal under Section 14(A)(2) of the
Scheduled Castes and Scheduled Tribes (Prevention of
Atrocities) Act, 1989 against the rejection of prayer for bail
Patna High Court CR. APP (SJ) No.2410 of 2025(4) dt.09-01-2026
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vide order dated 01.05.2025 passed by the learned
Additional Sessions Judge-I-cum-Special Judge, SC/ST Case No.
43 of 2025 in connection with SC/ST Case No. 43 of 2025
arising out of Jamui SC/ST P.S. Case No. 25 of 2024
registered for the offence/s punishable u/ss 126(2), 115(2),
76, 352 and 103(1) of the BNS and section 3(1)(r), 3(1)(s)
and 2(2)(va) of the SC/ST (POA) Act.
6. As per the prosecution case, the informant
Rinku Devi, has alleged that on 17.11.2024 the appellant
came to her house, abused her by taking her caste name,
tore her blouse and upon her raising alarm, pulled her down
and dragged her on the ground while threatening her with
dire consequences. It is further alleged that while leaving
the place, the appellant also damaged the newly constructed
house.
7. Learned counsel for the appellant submits that
the appellant has falsely been implicated in the present case
and that no such incident, as alleged, ever occurred. It is
further submitted that a perusal of Annexure-A/2, i.e., the
post-mortem report of Rinku Devi, would clearly show that
no external injury was found on the body of the deceased
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and that the opinion of the doctor was initially kept
reserved. Learned counsel further submits that from a
perusal of the case diary particularly paragraph no. 160, it is
evident that the FSL, Bhagalpur, vide report dated
11.11.2025, opined that the cause of death was cardio-
respiratory failure due to cardiogenic shock. It is thus
contended that the appellant has no connection whatsoever
with the death of the informant and admittedly, no injury
was found on the body of the deceased. Learned counsel
lastly submits that the appellant has clean antecedents and
has been in custody since 21.01.2025.
8. Learned Spl. P.P. for the State has
vehemently opposed the bail petition of the appellant.
9. Considering the aforesaid submissions and
facts of the case, the order passed by the learned Trial Court
dated 01.05.2025 passed in the present case is accordingly
set aside. Let the appellant above named be released on bail
on furnishing bail bonds of Rs.10,000/-(ten thousand) with
two sureties of the like amount each to the satisfaction of
the learned Court below where the case is
pending/successor court in connection with SC/ST Case No.
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43 of 2025 arising out of Jamui SC/ST P.S. Case No. 25 of
2024, subject to the following conditions:
(i) One of the bailors of the petitioner shall be his
close relative and the other shall be the local resident.
(ii) The petitioner shall remain physically present
in Court on each date of the trial.
(iii) In case of absence on two consecutive dates
or in violation of the terms of the bail, the bail bond of the
petitioner will be liable to be cancelled by the court
concerned.
(iv) If the petitioner is found involved in similar
nature of offence in future, the prosecution shall be at
liberty to move for cancellation of his bail bond.
(v) The learned Court below shall verify the
criminal antecedent of the petitioner and in case at any stage
it is found that the petitioner has concealed his criminal
antecedent, the court below shall take step for cancellation
of bail bond of the petitioner. However, the acceptance of
bail bonds in terms of the above-mentioned order shall not
be delayed for purpose of or in the name of verification.
10. The criminal appeal is allowed.
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11. It is made clear that the observation, if any,
made in this order, shall be of no bearing during the trial.
(Sourendra Pandey, J)
aditya/-
U T
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