Patna High Court
Ranjana DeviversusThe State of Bihar
- Decided
- Disposal
- ALLOWED
- Bench
- SATYAVRAT VERMA
Holding
The appeal is allowed and anticipatory bail is granted to the appellants subject to conditions under Section 482(2) of the CrPC.
Summary
The appellants, members of the Mandal family, appealed to the Patna High Court under Section 14‑A(2) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act against the lower court's refusal to grant anticipatory bail in a case alleging caste‑based assault, murder‑attempt and outraging modesty. They contended that they have clean antecedents, that the FIR was a retaliatory counter‑complaint, and that the injury report did not support the alleged knife attack on the informant's brother‑in‑law. The State, represented by a Special Public Prosecutor, opposed the bail. The High Court examined whether the allegations disclosed a prima facie case and whether the trial court erred in denying bail. Finding inconsistencies in the FIR and injury report and noting the appellants' clean record, the Court granted anticipatory bail subject to conditions under Section 482(2) of the CrPC and set aside the lower court's order, thereby allowing the appeal.
Issues considered
- Whether anticipatory bail should be granted under Section 14‑A(2) of the SC/ST Act in view of the allegations of caste‑based offences.
- Whether the FIR and injury report disclose a prima facie case justifying denial of bail.
- Whether the trial court erred in refusing anticipatory bail to the appellants.
Legislation cited
- Code of Criminal Procedure — s. 482(2)
- Indian Penal Code — s. 109, 115(2), 118(1), 126(2), 190, 191(2), 352, 76
- Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 — s. 14-A(2), 3(i)(r), 3(i)(s)
Subjects
- anticipatory bail
- SC/ST Act
- Section 14-A
- CrPC Section 482
- caste violence
- false implication
- FIR inconsistencies
- injury report
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL APPEAL (SJ) No.2771 of 2025
Arising Out of PS. Case No.-166 Year-2025 Thana- JAMUI District- Jamui
======================================================
1. Ranjana Devi S/O Damodar Mandal Village- Harla, P.S.- Jamui, Dist.- Jamui
2. Sachin Kumar S/O Damodar Mandal Village- Harla, P.S.- Jamui, Dist.-
Jamui
3. Guriya @ Guriya Kumari D/O Damodar Mandal Village- Harla, P.S.- Jamui,
Dist.- Jamui
4. Damodar Mandal S/O Late Balmiki Mandal Village- Harla, P.S.- Jamui,
Dist.- Jamui
5. Sakunti Devi W/O Late Balimiki Mandal Village- Harla, P.S.- Jamui, Dist.-
Jamui
... ... Appellant/s
Versus
1. The State of Bihar
2. Nitu Devi Wife of Murari Paswan Resident of Village- Harla, P.S- Jamui,
District- Jamui
... ... Respondent/s
======================================================
Appearance :
For the Appellant/s : Mr.Rajnish Chandra
For the Respondent/s : Ms.Usha Kumari 1
======================================================
CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
ORAL ORDER
4 30-04-2026 1. Heard learned counsel for the appellants and
learned Spl. P.P. for the State, Ms. Usha Kumari No. 1.
2. 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
order dated 13-6-2025 in A.B.P. No. 801 of 2025 passed by the
learned 1st District & Additional Sessions Judge, Jamui in
connection with Jamui P.S. Case No. 166 of 2025 registered for
Patna High Court CR. APP (SJ) No.2771 of 2025(4) dt.30-04-2026
2/4
the offences punishable under Sections 190, 191(2) 126(2),
115(2), 118(1), 109, 76 and 352 of the BNS as well as Sections
3(i)(r), 3(i)(s) of the SC/ST Act.
3. No one appears on behalf of the respondent No. 2.
4. Learned counsel for the appellants submits that the
appellants are persons with clean antecedent and appellant nos.
1, 3 and 5 are women and the informant alleges that on 13-3-
2025 at about 8 pm, all the accused persons including the
appellants came to her house and started abusing by taking caste
name, on objection Damodar Mandal gave orders to kill the
brother-in-law of the informant, when all the accused persons
started assaulting her brother-in-law by iron rod and knife and
dashed him on the ground, further Sachin assaulted her brother-
in-law by knife three times on head causing injury and when
informant came to save him, Gado Mandal and Sachin dashed
her on the ground and Ravi outraged her modesty and made
video of the same.
5. Learned counsel for the appellants submits that the
appellants have been falsely implicated in the instant case by the
informant. It is next submitted that from perusal of the
allegations as alleged in the FIR, it would manifest that the same
does not record any reason for the occurrence. It is further
Patna High Court CR. APP (SJ) No.2771 of 2025(4) dt.30-04-2026
3/4
submitted that from side of the appellants Jamui PS case No.
157 of 2025 dated 15-3-2025 was instituted against the
informant and her side, as such the instant FIR came to be
instituted by way of a counter-blast on 17-3-2025 alleging that
the occurrence took place on 13-3-2025. It is also submitted that
allegation of abuse is general and omnibus in nature, but then
Sachin is alleged to have assaulted the brother-in-law of the
informant by knife thrice on head causing injury on head, but
then from the order impugned, it would manifest that brother-in-
law suffered injury, which has been recorded as “1. Lacerated
wound below left eye size 2”x1/4”x Muscle deep 2. Redness on
left eye”. It is thus submitted that allegation of assault by knife
on head gets belied from the injury report as recorded in the
order impugned.
6. Learned Spl. P.P. for the State opposes the prayer
for anticipatory bail of the appellants.
7. Considering the aforesaid facts, let the appellants
above-named, in the event of their 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)
each with two sureties of the like amount each to the satisfaction
of the learned trial court where the case is pending/successor
Patna High Court CR. APP (SJ) No.2771 of 2025(4) dt.30-04-2026
4/4
court in connection with the aforesaid case, subject to the
conditions as laid down under Section 482 (2) of the BNSS.
8. Accordingly, the impugned order is set aside and
the appeal stands allowed.
(Satyavrat Verma, J)
Sumit/-
U T
Checking your session…