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Patna High Court

Ravi Singh @ Ravi KumarversusThe State of Bihar

Decided
Disposal
ALLOWED

Holding

The High Court set aside the refusal of anticipatory bail and granted it to the appellants subject to conditions.

Summary

The appellants, Ravi Singh and Bipul Kumar, were charged under several sections of the Bihar Penal Code and the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act for allegedly assaulting an informant and snatching his chain on 25 July 2025. They sought anticipatory bail under Section 14‑A(2) of the SC/ST Act after a Special Judge refused the relief. The appellants argued they have clean antecedents, the allegations lack caste‑based motive, and there is no injury report, contending false implication. The State opposed the bail, emphasizing the seriousness of the offences. The Patna High Court, applying Section 482(2) of the Criminal Procedure Code, set aside the lower court’s order and granted anticipatory bail subject to a bond and sureties, allowing the appeal.

Issues considered

  • Whether anticipatory bail can be granted in offences punishable under the SC/ST Act.
  • Whether the allegations constitute a caste‑based atrocity under the SC/ST Act.
  • Whether the facts justify denial of anticipatory bail.

Legislation cited

Subjects

  • anticipatory bail
  • SC/ST Act
  • caste based offence
  • false implication
  • bail conditions
  • criminal procedure

Judgment

                     IN THE HIGH COURT OF JUDICATURE AT PATNA
                                 CRIMINAL APPEAL (SJ) No.4293 of 2025
                        Arising Out of PS. Case No.-388 Year-2025 Thana- BYPASS District- Patna
                 ======================================================
           1.     Ravi Singh @ Ravi Kumar Son of Vijay Singh R/O Village - Marchi, P.S. -
                  Bypass District - Patna.
           2.    Bipul Kumar @ Dheeraj Kumar Son of Vijay SIngh R/O Village - Marchi,
                 P.S. - Bypass District - Patna.

                                                                                   ... ... Appellant/s
                                                       Versus
           1.    The State of Bihar Bihar
           2.    Chandan Paswan Son of Bambam Paswan R/O Village - Marchi, P.S. -
                 Bypass District - Patna.

                                                           ... ... Respondent/s
                 ======================================================
                 Appearance :
                 For the Appellant/s     :        Mr.Dinesh Kumar
                 For the Respondent/s    :        Mr.Sadanand Paswan, Spl. PP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
                                       ORAL ORDER

5   11-05-2026              1.    Heard learned counsel for the appellants and

                   learned Spl. P.P. for the State, Sri 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

                   order dated 18-9-2025 in A.B.P. No. 3551 of 2025 passed by the

                   learned Exclusive Special Judge S.C./S.T. (POA) Act, Patna in

                   connection with Bypass P.S. Case No. 388 of 2025 registered

                   for the offences punishable under Sections 126(2), 115(2), 109,
Patna High Court CR. APP (SJ) No.4293 of 2025(5) dt.11-05-2026
                                             2/3




          352, 125, 303(2) and 3(5) of the BNS as well as Sections 3(1)(r)

          (s) and 3(2)(va) of the SC/ST Act.

                    4.     Learned counsel for the appellants submits that the

          appellants are persons with clean antecedent and the informant

          alleges on 25-7-2025 at 5 PM while he was returning home

          when accused persons intercepted him near Marchi bridge and

          Ravi started abusing and used inappropriate words for his wife,

          on objection Ravi assaulted him by lathi causing injury on head

          and Bipul assaulted by brick below his knee causing injury and

          Ravi again assaulted by fist thrice causing injury near his eye

          and accused snatched his chain and fled when villagers

          gathered.

                    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

          informant alleges that while he was coming back home on 25-7-

          2025 when he was intercepted by the accused persons and Ravi

          abused but then it is not alleged that Ravi abused the informant

          by taking caste name, which amply demonstrates that the

          occurrence even if had taken place, did not take place on

          account of the fact that informant belongs to SC/ST community.
              Patna High Court CR. APP (SJ) No.4293 of 2025(5) dt.11-05-2026
                                                           3/3




                        It is further submitted that no doubt it is also alleged that Ravi

                        assaulted the informant by lathi causing injury on head thereafter

                        Bipul assaulted by brick causing injury below his knee, but then

                        there is no injury report on record. It is also submitted that

                        allegation of snatching chain is ornamental. It is next submitted

                        that on the way the informant dashed Ravi by bicycle when an

                        altercation took place in which both sides assaulted each other.

                                  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

                        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


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