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Patna High Court

Ranjan KumarversusThe State of Bihar

Decided
Disposal
ALLOWED

Holding

The High Court held that the trial court's refusal of anticipatory bail was unwarranted and allowed the appeal, granting anticipatory bail to the appellants.

Summary

The appellants, Ranjan Kumar and Pankaj Kumar, were charged under multiple provisions of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act in connection with a dispute over a vehicle purchase where the informant alleged caste-based abuse. The informants claimed that after a payment of Rs. 4,00,000, the vehicle was not transferred and later the informant was insulted at the appellants' garage. The appellants contended they have clean antecedents and that the allegations are false, emphasizing that the alleged abuse was not in public view and there were no independent witnesses. The trial court had refused anticipatory bail, prompting an appeal under Section 14‑A(2) of the SC/ST Act. The High Court set aside the lower court's order, finding no prima facie case under the Act and granting anticipatory bail subject to conditions under Section 482(2) of the CrPC. The appeal was therefore allowed.

Issues considered

  • Whether the allegations under the SC/ST (Prevention of Atrocities) Act disclose a prima facie case warranting denial of anticipatory bail.
  • Whether the High Court can set aside the trial court's refusal of anticipatory bail under Section 14‑A(2) of the SC/ST Act.

Legislation cited

Subjects

  • anticipatory bail
  • SC/ST Act
  • caste discrimination
  • false implication
  • vehicle dispute
  • criminal procedure

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                                  CRIMINAL APPEAL (SJ) No.3868 of 2025
                     Arising Out of PS. Case No.-19 Year-2025 Thana- SC/ST BETTIAH District- West
                                                       Champaran
                 ======================================================
           1.     Ranjan Kumar S/O Sri Ramesh Prasad Patel @ Ramesh Prasad Resident of
                  village- Parwatiya Nawka Tola, Ward No. 02, P.S- Bettiah Town, Distt.-
                  West Champaran.
           2.    Pankaj Kumar @ Pankaj Kumar Patel S/O Sri Prakash Prasad R/O Village-
                 Daniyal Parsauna, P.S- Sathi, Distt.- West Champaran.

                                                                                   ... ... Appellants
                                                       Versus
           1.    The State of Bihar
           2.    Pankaj Kumar Suman S/O Sri Ramshringar Prasad R/O Village- Damodara,
                 P.O and P.S- Guthani, Distt.- Siwan.

                                                           ... ... Respondents
                 ======================================================
                 Appearance :
                 For the Appellant/s     :        Mr. Sharad Kumar Verma, Advocate
                                         :        Mr. Harsha Shaswat, Advocate
                 For the Respondent/s    :        Mrs. Usha Kumari 1, Spl.P.P.
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
                                       ORAL ORDER

4   17-03-2026                     Heard learned counsel for the appellants and

                   learned Spl. P.P. for the State.

                                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 25.08.2025 passed by the learned 1 st Additional

                   Sessions Judge-cum-Special Judge S.C./S.T. (POA) Act, West

                   Champaran in connection with Bettiah SC/ST P.S. Case No. 19

                   of 2025 registered for the offences punishable under Sections

                   126(2), 115(2), 316(2), 318(4), 351(2), 352, 3(5) and 3(1)(r),

                   3(1)(s), 3(2)(va) of SC and ST (POA) Act.

                                3. Learned counsel for the appellants submits that the
Patna High Court CR. APP (SJ) No.3868 of 2025(4) dt.17-03-2026
                                             2/3




          case was taken up on 10.11.2025 and the learned Spl.P.P. was

          directed to inform the informant about the pendency of the case

          through the S.P./S.H.O.

                       4. Learned counsel for the appellants submits that the

          appellants are persons with clean antecedent and the informant

          alleges that on 10.08.2023 he gave Rs. 4,00,000/- by cheque to

          Ranjan Kumar for purchasing a Scorpio Vehicle, it is next

          alleged that after one month when he asked Ranjan Kumar to

          get the vehicle transferred in his name, he said the same will

          take time but later refused and the finance company people got

          the vehicle towed and took possession of the same, thereafter

          the informant went to the garage of Ranjan on 27.09.2024 when

          he was abused by taking caste name.

                       5. Learned counsel for the appellants submits that

          appellants have been falsely implicated in the instant case by the

          informant on account of dispute relating to purchase of vehicle.

          It is further submitted that even presuming what has been

          alleged is true without admitting then prima facie no offence

          under the SC/ST Act is made out as the informant alleged that

          he had gone to the garage of the appellants when he was abused

          by taking caste name, as such, the occurrence did not take place

          in public view nor the FIR does not even remotely suggest that
           Patna High Court CR. APP (SJ) No.3868 of 2025(4) dt.17-03-2026
                                                        3/3




                     the occurrence was witnessed by any independent witnesses.

                                  6. Learned Spl. P.P. for the State opposes the prayer

                     made by learned counsel for the appellants.

                                  7. In view of the submissions made by the learned

                     counsel for the parties, the order dated 25.08.2025 passed by the

                     learned 1st Additional Sessions Judge-cum-Special Judge

                     S.C./S.T. (POA) Act, West Champaran in connection with

                     Bettiah SC/ST P.S. Case No. 19 of 2025 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) each 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 Bettiah

                     SC/ST P.S. Case No. 19 of 2025 subject to the conditions as laid

                     down under Section 482 (2) of the BNSS.

                                  8. Accordingly the appeal stands allowed.



                                                (Satyavrat Verma, J)
Gaurav Sinha/-

U      T


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