Patna High Court
Satyam Kumar @ Satyam SinghversusThe State of Bihar
- Decided
- Disposal
- ALLOWED
- Bench
- SATYAVRAT VERMA
Holding
The appeal is allowed and anticipatory bail is granted to the appellant subject to the conditions imposed under Section 482(2) of the CrPC.
Summary
The appellant, Satyam Kumar, a 19‑year‑old resident of Patna, was implicated in a case involving the alleged theft of a motorcycle and the possession of a firearm, with charges under the SC/ST (Prevention of Atrocities) Act, the Arms Act and several sections of the Bihar Negotiable Instruments Act, 2023. He filed an appeal under Section 14‑A(2) of the SC/ST Act against the trial court’s refusal to grant anticipatory bail. The appellant argued that he had a clean record, was falsely implicated, and that the informant’s allegations did not specifically charge him. The State opposed the bail. The Patna High Court, after considering the submissions, set aside the trial court’s order and granted anticipatory bail subject to a bail bond of Rs.5,000 with two sureties and conditions under Section 482(2) of the CrPC. The appeal was allowed, and the appellant was released on anticipatory bail if arrested within six weeks.
Issues considered
- Whether the appellant is entitled to anticipatory bail under Section 14‑A(2) of the SC/ST (Prevention of Atrocities) Act.
- Whether the allegations in the FIR constitute a specific charge against the appellant sufficient to deny bail.
- Whether the trial court’s refusal to grant anticipatory bail was legally justified.
Legislation cited
- Arms Act — s. 25(1-b)a, 26, 35
- Bihar Negotiable Instruments Act, 2023 — s. 115(2), 126(2), 303(2), 3(5), 351(2), 352
- Criminal Procedure Code — s. 482(2)
- Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 — s. 14-A(2)
Subjects
- anticipatory bail
- SC/ST Act
- false implication
- bail under CrPC
- young adult offender
- arms possession
- scheduled caste atrocities
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL APPEAL (SJ) No.243 of 2025
Arising Out of PS. Case No.-188 Year-2024 Thana- NEORA District- Patna
======================================================
Satyam Kumar @ Satyam Singh Son of Yashwant Singh Resident of Village-
Basaudha, P.S.- Sadisopur, Distt.- Patna, Bihar
... ... Appellant/s
Versus
1. The State of Bihar
2. Sanket Kumar S/O Rajesh Paswan R/O Vill. Shrichandpur, P.s.- Neora,
Dist.- Patna.
... ... Respondent/s
======================================================
Appearance :
For the Appellant/s : Mr. Aakash Chaudhary, Advocate
For the Respondent/s : Mr. Sadanand Paswan, Special PP
======================================================
CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
ORAL ORDER
4 01-07-2026 1. Heard learned counsel for the appellant, Mr.
Aakash Chaudhary and learned Special P.P. for the State, Mr.
Sadanand Paswan.
2. No one appears on behalf of the informant.
3. This is an appeal under Section 14-A(2) of the
Scheduled Castes and Scheduled Tribes (Prevention of
Atrocities) Act, 1989 (hereinafter referred to as the “SC/ST
Act”) against the refusal of prayer for anticipatory bail vide
Patna High Court CR. APP (SJ) No.243 of 2025(4) dt.01-07-2026
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order dated 07.12.2024 in A.B.P. No. 4821 of 2024 passed by
the learned Exclusive Special Judge S.C./S.T. (POA) Act, Patna
Sadar in connection with Neora P.S. Case No. 188 of 2024
registered for the offences punishable under Sections 126(2),
115(2), 303(2), 352, 351(2) and 3(5) of the BNS, 2023, Section
25(1-b)a, 26 and 35 of the Arms Act read with Section 3(1) (r)
(s) of the SC/ST Act.
4. Learned counsel for the appellant submits that
appellant is a person with clean antecedent and is a young boy
aged about 19 years and the informant alleges that his
motorcycle was stolen on 07.10.2025 from his house, it is next
alleged based on suspicion that Bablu and Sahil were involved
in the occurrence, it is next alleged that on 08.10.2024 at 09:00
AM, the informant saw Bablu, Sahil and appellant sitting on his
bike, on inquiry, Bablu pointed pistol at him and the appellant
along with Sahil fled from the place of occurrence, it is further
alleged that Bablu was apprehended and from his possession
one pistol, two cartridges and a mobile was recovered and he
was handed over to the police.
5. Learned counsel for the appellant submits that
appellant has been falsely implicated in the instant case by the
informant. It is next submitted that no doubt, it is alleged that
Patna High Court CR. APP (SJ) No.243 of 2025(4) dt.01-07-2026
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motorcycle of the informant was stolen on 07.10.2024, but then
he raised suspicion against Bablu and Sahil and did not name
the appellant. It is next submitted that informant alleges that on
08.10.2024, he saw Bablu, Sahil and appellant riding the
motorcycle, thus, he enquired when Bablu pointed pistol at him,
it is thus submitted that as far as appellant is concerned, no
specific allegation is alleged against him. It is also submitted
that appellant is a young boy and if he is sent to judicial custody
in the nature of allegation as alleged in the FIR, his entire career
would get jeopardized and chances are bright that he may come
in contact with hardened criminals.
6. Learned Special P.P. for the State opposes the
appeal.
7. In view of the submissions made by the learned
counsel appearing on behalf of the appellant, the order dated
07.12.2024 in A.B.P. No. 4821 of 2024, is hereby set aside
and the appellant above-named, in the event of his arrest or
surrender within a period of six weeks from today, be released
on anticipatory bail on furnishing bail bonds of Rs. 5,000/-
(Rupees Five Thousand) with two sureties of the like amount
each to the satisfaction of the learned Trial Court where the case
is pending/successor court in connection with Neora P.S. Case
Patna High Court CR. APP (SJ) No.243 of 2025(4) dt.01-07-2026
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No. 188 of 2024 subject to the conditions as laid down under
Section 482 (2) of the BNSS.
8. One of the bailors of the appellant shall be his
father namely Yashwant Singh.
9. Accordingly, the appeal stands allowed.
(Satyavrat Verma, J)
Rishabh/-
U T
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