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Patna High Court

Ranjit SinghversusThe State of Bihar

Decided
Disposal
ALLOWED

Holding

The High Court held that the anticipatory bail must be granted where the FIR is vague and appears to be motivated by a civil land dispute, setting aside the lower court’s denial.

Summary

The appellants were accused of offences under the Bihar Negotiable Securities Act and the Scheduled Castes & Scheduled Tribes (Prevention of Atrocities) Act in connection with a land‑rental dispute, the informant alleging non‑payment of rent, assault, attempted outrage of modesty and theft of money and jewellery. Their application for anticipatory bail was rejected by the Exclusive Special Judge, SC/ST, Gaya. On appeal, the High Court examined whether the FIR was filed to settle a land dispute and whether the allegations were specific enough to justify denial of bail. The Court held that the allegations were vague, appeared to be motivated by the land dispute, and that the appellants were falsely implicated. Consequently, the order of the Special Judge was set aside, the appeal was allowed and the appellants were directed to be released on bail subject to conditions under Section 482(2) of the BNSS.

Issues considered

  • What is the appropriate standard for granting anticipatory bail under Section 482(2) of the BNSS in cases involving alleged offences under the SC/ST Act?
  • Whether the FIR filed by the informant is a genuine criminal complaint or a tool to settle a land‑rental dispute, thereby affecting the validity of the bail denial.

Legislation cited

Subjects

  • anticipatory bail
  • SC/ST Act
  • land dispute
  • false implication
  • Section 482
  • criminal procedure
  • bail conditions

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                                  CRIMINAL APPEAL (SJ) No.4359 of 2025
                          Arising Out of PS. Case No.-50 Year-2025 Thana- SC/ST District- Gaya
                 ======================================================
           1.     Ranjit Singh S/o Late Shambhu Singh @ Shambhu Sharan Singh R/o
                  Village- Rupaspur, P.S.- Panchanpur, District-Gaya
           2.    Ankit Kumar @ Ankit Raj S/o Ranjit Singh R/o Village- Rupaspur, P.S.-
                 Panchanpur, District-Gaya
           3.    Arun Kumar S/o Satyendra Chaudhary @ Satyendra Pasi R/o Village
                 Kasma, Mahiyarpur, P.S.- Panchanpur, District- Gaya.
           4.    Virendra Thakur S/o Rambilash Thakur R/o Village- Kurmawan, P.S.-
                 Konch, District- Gaya.
           5.    Kaushal Paswan S/o Late Ramjatan Paswan Resident of Village-
                 Mahiyarpur, P.S.-Panchanpur, District- Gaya.

                                                                                    ... ... Appellant/s
                                                        Versus
           1.    The State of Bihar
           2.    Babita Devi W/o Govind Chaudhary Resident of Village and Post- Amba,
                 District- Aurangabad, At present R/o Village-Kasma, P.S.- Panchanpur,
                 District- Gaya.

                                                           ... ... Respondent/s
                 ======================================================
                 Appearance :
                 For the Appellant/s     :        Mr. N. K. Agrawal- Sr. Advocate
                                                  Mr. Sudhir Kumar Sinha
                 For the Respondent/s    :        Mr. Binay Krishna- Spl.P.P.
                                                  Mr. Deepak Kumar- Advocate
                                                  Mr. Bishwanath Mahto- Advocate
                                                  Mr. Dhandev Kumar- Advocate
                                                  Mr. Dhananjay Kumar Gupta- Advocate
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE SATYAVRAT VERMA
                                       ORAL ORDER

7   24-06-2026                  1. Heard learned senior counsel for the appellants, the

                   learned Special Public Prosecutor for the State and the learned

                   counsel appearing on behalf of the informant.

                                2. The appellants have challenged the order dated

                   10.10.2025 passed by the learned Exclusive Special Judge,

                   SC/ST, Gaya Ji in connection with ABP No.262 of 2025 arising
Patna High Court CR. APP (SJ) No.4359 of 2025(7) dt.24-06-2026
                                             2/4




          out of SC/ST P. S. Case No.50 of 2025, instituted for the

          offences under Sections 126(2), 115(2), 74, 303(2), 351(2)(3),

          352 and 3(5)of the B.N.S. and Sections 3(1)(r)(s), 3(1)(w)(i),

          3(1)(f), 3(2)(va) of the Scheduled Castes & Scheduled Tribes

          (Prevention of Atrocities) Act, 1989, whereby their prayer for

          grant of anticipatory bail has been rejected.

                       3. The learned senior counsel appearing on behalf of

          the appellants submits that appellant no.1 has antecedent of six

          cases, but then was acquitted in one case and appellant no.3 has

          antecedent of one case and rest of the appellants have persons

          with     clean      antecedent       as    would       manifest   from   the

          supplementary affidavit and the informant alleges 14 katha land

          of her father-in-law bearing Khata no. 302 and Plot No. 1670 at

          Village Padariya, District Gaya was given to the accused

          persons on rent of Rs. 1,20,000/- for agriculture with consent of

          her brother-in-law but then no agreement was prepared and the

          land was handed over based on oral consent. It is next alleged

          that the accused persons were not giving a rent of the land and

          when informant demanded the rent, the accused persons started

          abusing and assaulting and even tried to outrage her modesty. It

          is next alleged that on 01.07.2025, when informant went to the

          Registry office Tekari for registering the land, the accused
Patna High Court CR. APP (SJ) No.4359 of 2025(7) dt.24-06-2026
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          persons snatched Rs. 50,000/- and gold chain.

                       4. The learned Senior counsel appearing on behalf of

          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 allegation as alleged in the

          FIR, It would manifest that allegation of abuse and assault is

          general and omnibus in nature. It is also submitted that if the

          allegations are perused minutely, it would manifest that the FIR

          has been instituted in backdrop of settling a land dispute, as

          such, the allegations do not inspire confidence.

                       5. The learned Special P.P. as well as the learned

          counsel appearing on behalf of the informant opposes the

          appeal.

                       6. Regard being had to the aforesaid submissions, the

          order dated 10.10.2025 is set-aside.

                       7. The appeal stands allowed.

                       8. The appellants, above-named, in the event of their

          arrest or surrender before the learned Court below within a

          period of eight weeks, are directed to be released on bail on

          their furnishing bail-bonds in the sum of Rs.5,000/- (Rupees

          Five Thousand) each with two sureties of the like amount each

          to the satisfaction of learned Exclusive Special Judge, SC/ST,
               Patna High Court CR. APP (SJ) No.4359 of 2025(7) dt.24-06-2026
                                                            4/4




                         Gaya Ji in connection with ABP No.262 of 2025 arising out of

                         SC/ST P. S. Case No.50 of 2025, subject to the conditions laid

                         down under Section 482(2) of the BNSS.



                                                    (Satyavrat Verma, J)
vikash/-

U          T


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