Patna High Court
Ravi Ranjan Kumar @ Ravi Ranjan Singh @ Tantan 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.
Summary
The appellant, Ravi Ranjan Kumar, was charged under several IPC sections and Sections 3(i)(r)(s) of the SC/ST (Prevention of Atrocities) Act for allegedly assaulting a complainant and stealing a vehicle key and money. He sought anticipatory bail, which was denied by the Special Judge. The appellant argued that he was falsely implicated, citing a police exoneration report and the complainant's refusal to oppose the bail application. The High Court considered the lack of opposition and the exonerating report, and, applying Section 14-A(2) of the SC/ST Act and Section 482(2) of the CrPC, granted anticipatory bail subject to monetary and surety conditions. Consequently, the impugned order refusing bail was set aside and the appeal was allowed.
Issues considered
- Whether anticipatory bail can be granted in a case under the SC/ST (Prevention of Atrocities) Act when the complainant does not oppose the application.
- Whether the trial court erred in refusing bail despite a police exoneration report and the complainant's non‑opposition.
- Whether the conditions imposed under Section 482(2) of the CrPC are appropriate in the grant of anticipatory bail.
Legislation cited
- Code of Criminal Procedure — s. 482(2)
- Indian Penal Code — s. 323, 34, 341, 379, 504, 506
- Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 — s. 14-A(2), 3(i), 3(r), 3(s)
Subjects
- anticipatory bail
- SC/ST Act
- false implication
- police exoneration
- bail conditions
- Criminal Procedure
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL APPEAL (SJ) No.319 of 2025
Arising Out of PS. Case No.-13 Year-2021 Thana- COMPLAINT CASE District- Lakhisarai
======================================================
Ravi Ranjan Kumar @ Ravi Ranjan Singh @ Tantan Singh Son of Mohan
Singh Resident of Village - Ramchandrapur, Police Station - Piparia, District -
Lakhisarai
... ... Appellant/s
Versus
1. The State of Bihar
2. Manoj Ram Son of Sakeldev Ram Resident of Village - Ghatkhusbha, P.S. -
Korma, District - Sheikhpura
... ... Respondent/s
======================================================
Appearance :
For the Appellant/s : Mr.Mukesh Kumar, Adv
For the Respondent/s : Mr.Sadanand Paswan, Spl. PP
Mr. Pankaj Kumar, Adv
======================================================
CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
ORAL ORDER
5 03-02-2026 1. Heard learned counsel for the appellant, learned
Spl. P.P. for the State, Sri Sadanand Paswan, and the learned
counsel appearing on behalf of the complainant.
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 26-9-2024 in A.B.P. No. 1068 of 2024 passed by the
learned 1st Additional District and Sessions Judge-cum-Special
Judge S.C./S.T. (POA) Act, Lakhisarai in connection with
Complaint Case No. 13C of 2021 registered for the offences
punishable under Sections 341, 323, 379, 504, 506 and 34 of the
Patna High Court CR. APP (SJ) No.319 of 2025(5) dt.03-02-2026
2/3
Indian Penal Code as well as Sections 3(i)(r)(s) of the SC/ST
Act.
3. Learned counsel for the appellant submits appellant
has antecedent of two cases and informant alleges that a mini
van was sanctioned to him under CM Transportation Scheme
and he had taken the vehicle for servicing to Mahindra
showroom when owner of the showroom asked the complainant
to stay for an hour and thereafter called 4-6 unknown accused
and assaulted and abused the complainant by taking caste name
and snatched key of the vehicle along with Rs. 5,000/-.
4. Learned counsel for the appellant submits that the
appellant has been falsely implicated in the instant case by the
complainant. It is next submitted that police after threadbare
investigation came to a considered conclusion that appellant is
innocent and thus submitted final form exonerating the appellant
of the allegation and the same was accepted by the learned trial
court, but based on protest, cognizance came to be taken.
5. At this stage, the learned counsel appearing on
behalf of the complainant submits that he has instruction not to
oppose the appeal.
6. Since the complainant does not want to oppose the
appeal, as such let the appellant above-named, in the event of
Patna High Court CR. APP (SJ) No.319 of 2025(5) dt.03-02-2026
3/3
his arrest or surrender before the learned trial trial court 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 the aforesaid case, subject to the conditions
as laid down under Section 482 (2) of the BNSS.
7. Accordingly, the impugned order is set aside and
the appeal stands allowed.
(Satyavrat Verma, J)
Sumit/-
U T
Checking your session…