Patna High Court

Upendra RavatversusThe State of Bihar

Decided: 12 January 2026
Disposal: DISPOSED
Bench: SATYAVRAT VERMA

Holding

Anticipatory bail was denied because the appellant’s alleged assault causing grievous injury did not merit the privilege under Section 14‑A(2) of the SC/ST Act.

Summary

The appellant, Upendra Ravat, was charged under several provisions of the Bihar Negotiable Instruments Act, 2023 and the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 for allegedly assaulting the son of an informant, causing multiple injuries, including one grievous injury. He sought anticipatory bail under Section 14‑A(2) of the SC/ST Act, but the Additional Sessions Judge refused the prayer. The appellant filed Criminal Appeal (SJ) No.4148 of 2025 challenging the refusal. The Patna High Court examined whether the seriousness of the alleged assault justified denial of anticipatory bail. Relying on the nature of the injuries and the relevant statutory provisions, the Court held that the appellant was not entitled to anticipatory bail. Consequently, the appeal was dismissed.

Issues considered

Whether anticipatory bail can be granted to the appellant under Section 14‑A(2) of the SC/ST Act in view of the alleged assault.
Whether the nature of the injuries (including a grievous injury) warrants denial of anticipatory bail.
Interpretation of the relevant provisions of the SC/ST Act and the Bihar Negotiable Instruments Act, 2023 in the context of offences against a scheduled caste/tribe individual.

Legislation cited

B.N.S., 2023 — s. 109, 115(2), 117(2), 118(1), 126(2), 303(2), 3(5), 351(2), 352
Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 — s. 14-A(2), 3(1)(r)(s), 3(2)(va)

Subjects

anticipatory bail
SC/ST Act
assault
grievous injury
criminal appeal
scheduled caste
scheduled tribe
denial of bail

Judgment

                     IN THE HIGH COURT OF JUDICATURE AT PATNA
                                 CRIMINAL APPEAL (SJ) No.4148 of 2025
                  Arising Out of PS. Case No.-62 Year-2025 Thana- MOHAMMADPUR District- Gopalganj
                 ======================================================
                 Upendra Ravat S/O Late Vijay Ravat @ Late Bija Ravat R/O Village-
                 Mangalpur Dhobi Tola, P.S.- Mohammadpur, District- Gopalganj

                                                                               ... ... Appellant/s
                                                      Versus
           1.    The State of Bihar
           2.    Dilip Baitha S/O Birendra Baitha R/O Village- Mangalpur Dhobi Tola, P.S.-
                 Mohammadpur, District- Gopalganj

                                                           ... ... Respondent/s
                 ======================================================
                 Appearance :
                 For the Appellant/s    :        Mr. Lokesh Kumar Singh
                 For the Respondent/s   :        Ms. Usha Kumari 1
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
                                       ORAL ORDER

2   12-01-2026                 1. Heard learned counsel for the appellant and the

                   learned Special P.P. Ms. Usha Kumari No.1.

                               2. In view of the grounds taken in I.A. No.1/2025, the

                   delay of 8 days in filing the appeal is condoned.

                               3. I.A. No.1/2025 is allowed.

                               4. 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 11.06.2025 in A.B.P. No. 936/2025, passed by the

                   learned Additional Sessions Judge-XI-cum-Special Judge,

                   SC/ST Act, Gopalganj in connection with Mohammadpur P.S.
             Patna High Court CR. APP (SJ) No.4148 of 2025(2) dt.12-01-2026
                                                          2/2




                       Case No.62/2025, registered under Sections 126(2), 115(2),

                       118(1), 117(2), 109, 303(2), 352, 351(2) and 3(5) of the B.N.S.,

                       2023 as well as Sections 3(1)(r)(s), 3(2)(va) of the SC/ST (POA)

                       Act, 1989.

                                    5. In the nature of allegation as alleged in the FIR, the

                       Court is not inclined to extend the privilege of anticipatory bail

                       to the appellant as the appellant is alleged to have assaulted the

                       son of the informant by tangi on face causing injury. It is also

                       fairly submitted by the learned counsel appearing on behalf of

                       the appellant that the injured suffered four injuries, out of

                       which, three injuries are simple in nature and one injury is

                       opined to be grievous.

                                    6. The appeal is dismissed.



                                                  (Satyavrat Verma, J)
amit/-

U        T

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